Minimum level of taxation for large multinational groups

We would like to thank the EU Commission for the opportunity to submit our comments on the Commission’s Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. In this respect, please find attached our observations.

We are pleased to respond on behalf of the Deloitte firms in the European Union to the European Commission Public Consultation on the Proposal published by the European Commission on 22 December 2021 for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union (the “Proposal”) and welcome the opportunity for debate on this topic.

EPRA gladly takes the opportunity to comment on the Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the European Union, as we followed closely the negotiations at the OECD level.

With regard to the practical impact, the EACB asks the Commission to clarify: • treatment of deferred taxes, given that - for purpose of determining turnover, taxes and the tax base - covered taxes include not only local taxes on income and earnings, but also complex corrections for deferred taxes (Articles 19-21); • considering that the effective tax rates (ETR) are derived based on the country-by-country reports…

EFAMA is grateful for the opportunity to comment on the Pillar Two proposal. We are sharing our comments with the Commission, with all Fiscal Attachés/Ministers of Finance of the 27 EU Member States, as well as with the OECD Secretariat.

CFE Tax Advisers Europe has issued an Opinion Statement on the ongoing process that seeks to enact the Pillar 2 political agreement into the legal order of the EU and other states. CFE welcomes the historic agreement on the global tax reform with a key objective of stabilising the international corporate tax framework arising from the challenges of the digitalising economy.

Invest Europe is pleased to see that the European Commission’s proposal on a minimum level of taxation for large multinational groups closely follows the OECD Model Rules for Pillar Two. When taxing companies which are part of global value chains, the global aspects must be taken into account.

The Federal Chamber of Tax Advisers (BStBK) represents the interests of more than 100 000 tax advisers in Germany vis-à-vis the Bundestag, the Bundesrat, the Federal Ministries, the heads of civil service, the courts and the institutions of the EU and the OECD.

Filed in German · English published by the European Commission

The European Community Shipowners’ Associations (ECSA) welcomes the opportunity to give feedback on the Commission's Proposal for a directive to implement the OECD Pillar Two rules. ECSA would like to draw the attention of the Regulators that the EC Proposal in its current form may lead to competitive disadvantages and distortions.

Insurance Europe welcomes the opportunity to provide feedback through the “Have your say” tool and wishes to raise some critical concerns and highlight the need for clarifications of some key elements of the EC’s work on the proposal for a Directive on ensuring a global minimum level of taxation for multinational groups in the EU, and for the implementation of the OECD Model Rules.

Oxfam closely followed the negotiations at the OECD Inclusive Framework and expressed its concerns about the lack of ambition and the unfairness of the global tax deal. Requests from low-income countries were poorly included and analyses show that the new rules benefit rich countries mainly.

The AgriFish Agency estimates that the political agreement on a minimum global taxation could become a strong foundation for coherent international rules, of which the 137 countries can be proud. This can ensure a more level playing field for many Danish export-oriented companies.

Filed in Danish · English published by the European Commission

The Mouvement des Entreprises de France supports the global minimum tax project, in that it can limit certain excessive tax differences between countries. However, this important political objective must not be achieved at the expense of European (including French) companies.

ETNO and the GSMA, in representation of the European telecoms sector, welcome the possibility to provide their comments in response to the European Commission’s public consultation on Pillar 2 Directive Proposal (COM(2021)823). Our views are detailed in the attached position paper.

Please find attached Independent Retail Europe's comments on the Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. Independent Retail Europe is the voice of groups of independent retailers, bringing together 23 groups of independent retailers and national associations representing them.

KPMG member firms in the EU are pleased to provide comments in the attached document on the European Commission’s proposal for a Council Directive on ensuring a global minimum level of taxation for large multinational groups in the Union. KPMG supports the EC’s efforts in ensuring a harmonized implementation in the EU of the OECD GloBE Model Rules under Pillar Two, while safeguarding compliance with EU law.

eco — Verband der Internetwirtschaft e.V. supports the OECD agreement and the accompanying implementation efforts of the European Commission. The international agreement on solving taxation issues and the associated implementation at European level address many of the concerns raised by the internet economy in the debate so far. According to eco, both a European (e.g.

Filed in German · English published by the European Commission

For EAPN Netherlands this is a first, good, step to rebuilt the taxsystem that is too long based on supporting the companies and using it as a kind of competition model to spawn the big companies and the rich. It is really a time for a change. The next step that EAPN NL feels as necessary is to introduce the Financial Transaction Tax in 2022.