2023-06-21-KPMG_s_EU_Tax_Centre-Euro_Tax_Flash_from_KPMG_s_EU_Tax_Centre_4页_303kb

KPMG EU Tax Centre - Euro Tax Flash: EU Taxation Developments - Analysis Summary

1. Background

• Introduces new own resources for the EU budget.
• Adjusts the first basket of proposed own resources initiated in December 2021.
• Focuses primarily on a temporary company profits-based own resource.
• Previous own resources were aimed at reimbursing NextGenerationEU borrowing, following agreements in 2020.
• The first basket (suggesting CBAM, ETS, OECD Pillar One contributions) included a proposal to enter into force January 1, 2023, with deliberation by July 1, 2022. The second basket's proposal was initially expected for June 2024.
• The BEFIT proposal is expected on September 12, 2023, potentially linking to the temporary company profits levy.

2. EC Proposal Details (Second Basket)

· New Temporary Own Resource on Company Profits

*   **Definition:** A statistical own resource based on national accounts statistics (ESA), specifically gross operating surplus of the financial and non-financial corporations sector.
*   **Nature:** Not a new tax on companies, but requires Member States to transfer ~0.5% of this surplus monthly into the EU budget.
*   **Applicability:** Temporary, until a contribution based on the BEFIT initiative is proposed and agreed by all Member States.
*   **Revenue:** Estimated ~€16 billion/year from 2024 (based on 2018 data).

· Adjusted ETS-based Own Resource

*   **Action:** Increase call rate from 25% to 30% due to rising carbon prices.
*   **Revenue:** Estimated ~€7 billion/year from 2024, increasing starting 2028 under new ETS rules.

· Adjusted CBAM-based Own Resource

*   **Status:** Largely unchanged from the December 2021 proposal (adjustments mainly for text alignment).
*   **Arrangement:** 75% of CBAM revenues go to the EU budget.
*   **Revenue:** Estimated ~€1.5 billion/year from 2028 onward.

· Pillar One-based Own Resource

*   **Status:** Maintained, based on the 15% of taxable profits re-allocated per Member State under Pillar One.
*   **Revenue:** Estimated between €2.5B and €4B annually. Delays in international Pillar One talks make its implementation uncertain.

· Other Omitted Elements

• BEFI: Contribution expected following the BEFI proposal.
• Key Missing Element: A Financial Transaction Tax (FTT) based own resource is notably absent, despite previous mention as a potential revenue source.

3. Next Steps and Implementation

• The proposal requires a unanimous decision by the European Council and a non-binding opinion from the European Parliament.
• Timeline Key Dates:
  • 2024: Levy on the statistical own resource on company profits and gain from (existing ETS covering) stationary installations, maritime and aviation.
  • January 1, 2028: Levy from CBAM and the new ETS covering buildings, road transport and other sectors.
• Implementation: Requires Member State ratification in accordance with national constitutional requirements.

4. KPMG Comment (ETC)

• EC Gives Longer Deadline: Prompted earlier than initially planned, excluding FTT.
• Parliament's Role: The European Parliament supports broader new revenue streams (BEFIT, FTT, crypto assets, etc.) for the EU budget, referencing its May 10th 2023 resolution.
• EC's Stance: Prioritizes statistical resources (especially the temporary corporate profits levy) due to feasibility. FTT talks have stalled since 2021. An EU-wide crypto asset tax faces practical hurdles (disparate national approaches, WTO compliance). A "Fair border mechanism" also presents design, implementation, and WTO compliance challenges.