EU eyes tax overhaul

19 May, 2021

By ECCT staff writers

The European Commission has adopted a “Communication on Business Taxation for the 21st century” aimed at promoting “a robust, efficient and fair business tax system” in the European Union. According to a press release on the EU’s official website, Europa, the communication sets out both a long-term and short-term vision to support Europe's recovery from the Covid-19 pandemic and to ensure adequate public revenues over the coming years. Further, it aims to create an equitable and stable business environment, which can boost sustainable and job-rich growth in the EU and increase open strategic autonomy.

The communication is part of a wider EU tax reform agenda for the coming years and takes account of the progress made in the G20/OECD discussions on global tax reform. In addition to the corporate tax reforms set out in the communication, the commission will soon present measures to ensure fair taxation in the digital economy. For example, the commission will propose a digital levy, which will serve as an EU resource. The commission will also soon propose a review of the Energy Taxation Directive and the Carbon Border Adjustment Mechanism (CBAM), in the context of the “FitFor55” package and European Green Deal.

According to the press release, the Commission will present by 2023 a new framework for business taxation in the EU, which will reduce administrative burdens, remove tax obstacles and create a more business-friendly environment in the single market. The “Business in Europe: Framework for Income Taxation” (or BEFIT) will provide a single corporate tax rulebook for the EU, providing for fairer allocation of taxing rights between EU member states. BEFIT will cut red tape, reduce compliance costs, minimise tax avoidance opportunities and support EU jobs and investment in the Single Market. BEFIT will replace the pending proposal for a Common Consolidated Corporate Tax Base, which will be withdrawn. The commission will launch a broader reflection on the future of taxation in the EU, which will culminate in a Tax Symposium on the “EU tax mix on the road to 2050” in 2022.


The communication also defines a “tax agenda” for the next two years, with measures that promote productive investment and entrepreneurship, better safeguard national revenues, and support the green and digital transitions. This builds on the roadmap set out in the Tax Action Plan, presented by the commission last summer. Measures will include: Ensuring greater public transparency by proposing that certain large companies operating in the EU publish their effective tax rates; tackling the abusive use of shell companies through new anti-tax avoidance measures; supporting the recovery by addressing the debt-equity bias in the current corporate taxation, which treats debt financing of companies more favourably than equity financing. This proposal will aim to encourage companies to finance their activities through equity rather than turning to debt.

The commission also adopted a recommendation on the domestic treatment of losses, which prompts member states to allow loss carry-back for businesses to at least the previous fiscal year. This will benefit businesses that were profitable in the years before the pandemic, allowing them to offset their 2020 and 2021 losses against the taxes they paid before 2020. This measure will particularly benefit SMEs.

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