A historic process is under way in the EU with the unanimous agreement to implement the Minimum Tax Directive (Pillar Two), and a forthcoming proposal for the apportionment of corporate tax income (Pillar One). This will put an end – at least for the EU – to the current system of international coordination on corporate income tax, which is based on the individuation of separate entities, the reference to intra-group transactions, and the ‘arm’s length principle’ for transfer pricing between related parties.
Set up in February 2022 to examine the two-Pillar solution agreed at OECD level, a dedicated CEPS Task Force brought together a balanced working group of industry experts, academia, EU institutions and national authorities to engage in both research and several high-level discussions.
The report, ‘EU corporate taxation in the digital era – The road to a new international order’, discusses the critical points in the design of the two-Pillar solution agreed at OECD level. The focus is primarily on Pillar Two, where there has been significantly more progress than Pillar One. The report puts forward concrete recommendations on how to improve the functioning of Pillar Two and how to implement the Business in Europe: Framework for Income Taxation (BEFIT) in the EU, stressing the importance of simplicity, the reduction of compliance costs and uniformity.
This seminar will discuss how international cooperation on corporate taxation can be achieved and how Pillar Two will be implemented in Europe and coordinated with BEFIT.
AGENDA
OPENING REMARKS
Vieri Ceriani, Chair of the Task Force; Former Under-Secretary of State, Italian Ministry of Finance and Economy (Monti Government)
PRESENTATION OF THE REPORT
Apostolos Thomadakis, Research Fellow, ECMI and CEPS
FIRST REACTION
Gerassimos Thomas, Director General, DG TAXAUD, European Commission
DISCUSSION
- Jaime Salmerón, Head of EU Tax Policy and CFO Netherlands, Repsol
- Marlies de Ruiter, Partner, Global International Tax Policy Leader, EY
- Maarten de Wilde, Professor of International and European Tax Law, Erasmus University Rotterdam
MODERATOR
Elodie Lamer, Journalist, Tax Notes