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EU: Infringement procedures closed regarding Pillar Two minimum tax transposition

Closed infringement procedures against Spain, Cyprus, Portugal, Lithuania, Estonia, Greece, Poland, and Latvia 

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december 17, 2025

The European Commission on December 11, 2025, announced that it has closed infringement procedures against Spain, Cyprus, Portugal, Lithuania, Estonia, Greece, Poland, and Latvia for failures to transpose Council Directive (EU) 2022/2523 (the EU Minimum Tax Directive) into legislation. All EU member states were required to comply with the directive by December 31, 2023.

Proceedings were initiated in January 2024 against nine member states for not fully notifying the Commission of national measures transposing the directive.

Read a December 2025 report prepared by KPMG’s EU Tax Centre

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