New tax rules for multinational companies operating in EU have come into effect

New EU rules came into effect on January 1 2024 introducing a minimum rate of effective taxation of 15 per cent for multinational companies active in EU member states, with the rules applying to multinational enterprise groups and large-scale domestic groups in the EU, with combined financial revenues of more than 750 million euro a year, the European Commission (EC) said.

They will apply to any large group, both domestic and international, with a parent company or a subsidiary situated in an EU member state.

“The framework will bring greater fairness and stability to the tax landscape in the EU and globally, while making it more modern and better adapted to today’s globalised, digital world,” the EC said.

The entry into force of the minimum effective taxation rules, unanimously agreed by EU member states in 2022, formalises the EU’s implementation of the so-called “Pillar 2” rules agreed as part of the global deal on international tax reform in 2021, the Commission said.

“While almost 140 jurisdictions worldwide have now signed up to those rules, the EU has been a front-runner in translating them into hard law.”

By lowering the incentive for businesses to shift profits to low-tax jurisdictions, Pillar 2 curbs the so-called “race to the bottom”—the battle between countries to lower their corporate income tax rates in order to attract investment, the EC said.

“It is already delivering results, with a number of zero tax jurisdictions around the world having announced the introduction of a corporate income tax for the companies in scope,” the Commission said.

The directive includes a common set of rules on how to calculate and apply a “top-up tax” due in a particular country should the effective tax rate be below 15 per cent.

If a subsidiary company is not subject to the minimum effective rate in a foreign country where it is located, the member state of the parent company will also apply a top-up tax on the latter.

In addition, the directive ensures effective taxation in situations where the parent company is situated outside the EU in a low-tax country which does not apply equivalent rules, the EC said.

(Photo: Filippo Vicarelli/

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