With the release of this proposal, the Commission is replicating the OECD / BEPS Inclusive Framework (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Model Rules that came live in December 2021 and addresses how Member States will implement them in a coherent and consistent way across the EU. The work of the Commission and the alignment with the work of the OECD / BEPS Inclusive Framework are to be welcomed.

EFAMA very much welcomes the agreement reached to include investment funds in the list of Excluded Entities, in particular: i) paragraphs 135 to 140 of the report on Pillar One blueprints; ii) paragraphs 71 to 83 of the report on Pillar Two blueprints.

EFAMA fully supports the Commission’s initiatives to ensure a global minimum level of taxation for multinational groups, provided the tax neutrality in respect of investment funds is preserved as a “widely recognized principle that underpins the design of the international tax rules”.