European Commission proposes tax Directive for implementing BEPS 2.0 Pillar Two Model Rules in the EU

Executive summary

On 22 December 2021, the European Commission (the Commission) published a legislative proposal for a Directive setting forth rules to ensure a global minimum level of taxation for multinational groups (the draft Directive). The proposed rules are generally consistent with the agreement reached by the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) on 8 October 2021 (the October Statement),¹ and closely follow the Model Rules published on 20 December…