The European Commission has issued a Notice on the Side-by-Side arrangement agreed upon by the BEPS Inclusive Framework on 5 January 2026, including new and extended safe harbors. The Commission Notice formally acknowledges the agreement and confirms its application in the context of Council Directive (EU) 2022/2523. In particular, it is explained that all EU Member States have consented to the new and extended safe harbors and, therefore, they may be applied under the Directive.
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