EU: Five EU Member States issue joint statement committing to implementing global minimum tax (Pillar Two)

France, Germany, Italy, Spain and the Netherlands

France, Germany, Italy, Spain and the Netherlands

The governments of France, Germany, Italy, Spain and the Netherlands today, 9 September 2022, issued a joint statement [PDF 88 KB] to express their full commitment to implementing the GloBE rules that provide for a global minimum tax (Pillar Two).

According to the release, the five EU Member States are fully determined to introduce rules on global minimum effective taxation in 2023, by any possible legal means. The statement builds on the German government’s announcement (German) [PDF 127 KB] (3 September 2022) on the intention to start with the implementation process at a national level in order to partially finance a new package of measures to provide relief from rising inflation and energy prices.

Previously, the Economic and Financial Affairs Council of the EU (ECOFIN) failed to reach a political agreement on the revised compromise text due to reservations from Hungary (for more details, read TaxNewsFlash). 

KPMG observation

While confirming that the primary goal is to reach consensus by all EU Member States, today’s statement does not further clarify how the countries will actually achieve implementation. If Hungary or other EU Member States continue to veto the initiative in the upcoming ECOFIN meeting of 4 October 2022, one possible solution could be for the proposal to be adopted under the so-called “enhanced cooperation” procedure, whereby a minimum of nine EU Member States can choose to move ahead. Alternatively, the EU Member States may seek to proceed unilaterally.

In addition, the joint statement notes that the five countries are also fully committed to completing the work on Amount A of the OECD Pillar One solution to reallocate profits of multinational enterprises to market jurisdictions with the objective of signing a Multilateral Convention by mid-2023.

For more information, contact a tax professional with KPMG’s EU Tax Centre: 

Raluca Enache |

Vinod Kalloe |

Cormac Golden |

Marco Dietrich |


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