2022-03-08-KPMG_s_EU_Tax_Centre-Euro_Tax_Flash_from_KPMG_s_EU_Tax_Centre_3页_326kb

KPMG member firms responded to the European Commission's public consultation on the proposed EU Directive for a minimum level of taxation under BEPS 2.0, specifically the GloBE Rules from OECD's Pillar Two. The proposal aims to incorporate these rules into EU law, with a potential implementation date of January 1, 2023. KPMG supports the Commission's efforts for harmonized application but stresses the need for additional clarifications to align with OECD Model Rules and Commentary, ensuring legal certainty and addressing challenges like administrative burdens, penalties, and transitional arrangements for in-scope groups. Key concerns include inconsistencies in interpretation across the EU and the implementation timeline. While transitional relief is available for filing obligations, achieving unanimous EU agreement remains uncertain, with the French Presidency prioritizing its adoption.

The report was prepared by KPMG's EU network and offers further insights on areas requiring alignment and guidance for effective taxpayer certainty.