The June edition covers the EU Direct Tax Omnibus and DAC Recast proposals, the OECD webinar on the Global Minimum Tax, Ireland's EU Council Presidency tax priorities, OECD transfer pricing consultations, ECOFIN conclusions, AMLA's inaugural conference and more.
EU Tax Simplification Agenda: Direct Tax Omnibus & DAC Recast
On 24 June 2026, the European Commission published the long-anticipated proposal for a Direct Tax Omnibus Directive and a proposal to recast the Directive on Administrative Cooperation, as part of its wider EU Tax Simplification Agenda. The Commission estimates that the legislative package could reduce compliance costs for businesses by approximately €8 billion annually.
Direct Tax Omnibus
The Omnibus would amend six existing directives: the Parent-Subsidiary Directive, the Interest and Royalties Directive, the Tax Merger Directive, the Anti-Tax Avoidance Directive (ATAD), the Dispute Resolution Mechanisms Directive and the FASTER Directive. A central element is the abolition of withholding tax barriers on cross-border payments of dividends, interest and royalties between associated companies within the EU, together with the extension of the Parent-Subsidiary Directive to pension institutions. The proposal introduces a common minimum standard for the tax treatment of investments in R&D-related tangible assets, with immediate deduction of qualifying expenditure or deduction over the following four tax periods.
The proposal also simplifies the Interest Limitation Rule (mandatory 30% EBITDA threshold and €3 million de minimis, inflation adjustment, mandatory group escape rule and carry-forward), reforms the CFC rules by making Model A the only permitted approach across the EU (with a general exemption for taxpayers within the scope of Pillar Two, subject to safeguards), removes imported hybrid mismatch rules from ATAD and updates the General Anti-Abuse Rule so it applies to all direct taxes. It further expands the Tax Merger Directive to all forms of corporate reorganisations recognised under EU company law and amends the Dispute Resolution Mechanisms Directive. As the proposal is based on Article 115 TFEU, its adoption will require unanimous agreement by the Member States.
DAC Recast
The DAC Recast consolidates the original Directive and its eight amendments into a single text with targeted changes to DAC1, DAC4, DAC6, DAC7 and DAC9. For DAC6, Pillar Two groups would be excluded where arrangements do not reduce taxation below the 15% minimum rate, Category A hallmarks would be removed and the intermediaries' reporting deadline extended from 30 to 90 days. For DAC7, the monetary reporting threshold rises from EUR 2,000 to EUR 3,000. DAC4 and DAC9 notifications would be replaced by a single notification for multinational groups, and DAC1 would be strengthened with broader access to national registers and a new EU-wide TIN verification system. The Commission estimates annual compliance cost savings of up to EUR 340 million for DAC6, EUR 452 million for DAC7 and EUR 270 million for DAC4/DAC9.
OECD Webinar to Examine the Economic Impact of the Global Minimum Tax
On 15 July, the OECD will host a webinar presenting the latest findings from its 2026 Economic Impact Assessment of the Global Minimum Tax, including analysis of the recently agreed Side-by-Side package. The webinar will examine evidence on effective tax rates, profit shifting and tax revenues, and will present preliminary findings based on post-implementation data. The session will be led by OECD Centre for Tax Policy and Administration officials, including Kurt Van Dender and Pierce O'Reilly, alongside economists Laura Arnemann and Felix Hugger.
Ireland Launches 2026 Presidency of the Council of the EU & Sets Tax Priorities
In late June, Ireland formally launched its Presidency of the Council of the European Union, running from 1 July to 31 December 2026, with three overarching priorities: competitiveness, values and security. In taxation, the Irish Presidency will prioritise the EU tax simplification agenda, including work to conclude the DAC recast and progress the Tax Simplification Omnibus package. Ireland will also oversee the work of the Code of Conduct Group (Business Taxation), including the October 2026 update of the EU list of non-cooperative jurisdictions, monitor implementation of the OECD Pillar Two rules and the EU "side-by-side" solution, and progress files including the proposed CBAM extension, the Temporary Decarbonisation Fund, revisions to the Tobacco Tax Directive and potential amendments to the EU VAT framework.
OECD Launches Consultation on Revised Transfer Pricing Guidelines on Intra-Group Services & Amendments to Digital Platform Reporting Rules
In June, the OECD launched a public consultation on proposed revisions to Chapter VII of the OECD Transfer Pricing Guidelines on intra-group services, seeking to modernise the chapter and align it with Chapters I–III while preserving arm's length principles. Key elements include expanded guidance on the benefit test and accurate delineation of intra-group service transactions, updated guidance on methodologies (with no presumption in favour of cost-based methods), and new examples addressing intangibles, R&D, data analytics and AI-related activities. The simplified approach for low value-adding intra-group services, including the 5% mark-up, is largely retained. Comments are invited until 22 July 2026, with a public consultation meeting scheduled for November 2026 in Paris.
The OECD also launched a public consultation on targeted amendments to its Model Reporting Rules for Digital Platforms, proposing to replace the current dual threshold with a single monetary threshold of EUR 3,000, clarify the definitions of "Platform" and "Platform Operator", exclude pure payment processors, limit duplicate reporting and introduce a new "Related Entity" concept. Comments are invited until 14 August 2026.
ECOFIN Reviews EU Tax Priorities & Endorses Code of Conduct Group Progress
At its meeting on 12 June 2026, the ECOFIN Council approved its six-monthly report on tax issues and adopted conclusions on the work of the Code of Conduct (Business Taxation) Group during the Cyprus Presidency. The report notes the May 2026 general approach on granting the EPPO and OLAF access to VAT information held at EU level, continuing discussions on the Tobacco Taxation Directive recast, and ongoing work under the Council's tax decluttering agenda. The Commission announced its intention to withdraw several pending direct tax proposals, including the Unshell Directive, DEBRA, the Transfer Pricing Directive and the Financial Transaction Tax proposal. The Council also reviewed the OECD/G20 Inclusive Framework implementation, the January 2026 Pillar Two "side-by-side" package and negotiations on the UN Framework Convention on International Tax Cooperation.
AMLA Hosts Inaugural Conference on the Future of the EU AML Framework
The EU Anti-Money Laundering Authority held its inaugural conference in Frankfurt in June, outlining plans for the implementation of the EU's new Anti-Money Laundering Framework, applicable from 10 July 2027. The new regime introduces a single EU rulebook and will see AMLA directly supervise approximately 40 high-risk cross-border financial institutions. Speakers highlighted that around €110 billion is laundered annually in the EU while only around 1% of criminal proceeds are confiscated, and discussed the move from high-volume reporting towards higher-quality intelligence, common supervisory methodologies, Joint Supervisory Teams and a central data hub. Lawyers, accountants, auditors and tax advisers were identified as important actors in detecting suspicious activity. Emerging risks linked to crypto-assets, artificial intelligence and digital financial services were also examined.
EU Parliament Reviews the Future of the VAT Reverse Charge Mechanism
The European Parliament Subcommittee on Tax Matters and the Committee on Budgetary Control held a joint exchange of views on cooperation in the fight against VAT fraud, examining the future of the optional VAT Reverse Charge Mechanism and Quick Reaction Mechanism. An EPRS study estimates that Missing Trader Intra-Community fraud continues to cost the EU between €12.5 billion and €32.8 billion annually, while 75–80% of tax administrations applying the RCM reported reductions in fraud. The Commission confirmed it intends to present a legislative proposal after the summer to extend both mechanisms beyond 31 December 2026, with broad agreement that the RCM should continue as a targeted anti-fraud measure until the VAT in the Digital Age package becomes fully operational in July 2030.
OECD Tax & Development Conference Examines Global Minimum Tax Safe Harbours & Tax Certainty Initiatives
The OECD Tax and Development Days 2026 conference was held virtually under the theme "From Rules to Results: Turning Tax Policy into Development Impact". Discussions centred on the Inclusive Framework's Side-by-Side package, which introduces a safe harbour accommodating certain alternative minimum tax systems consistent with the 15% standard and a simplified effective tax rate safe harbour, alongside more favourable treatment of substance-based tax incentives. Further sessions examined transfer pricing simplification (including Amount B), the growth of the Mutual Agreement Procedure — with jurisdictions handling MAP cases roughly doubling to about 100 by 2024 — and broader tax and development topics including taxpayer trust, tax administration modernisation and the use of data and technology.
CFE Opinion Statement on Distinguishing Between Supplies of Goods & Services for VAT Purposes
CFE Tax Advisers Europe published an Opinion Statement examining the distinction between supplies of goods and supplies of services under EU VAT law. The Statement observes that digital business models, customised products and hybrid arrangements have made the distinction increasingly difficult to apply, resulting in divergent national interpretations and legal uncertainty. CFE calls on the European Commission and the VAT Committee to provide clearer guidance on common borderline cases and to codify principles established by CJEU jurisprudence.
OECD Publishes Enhanced Monitoring Report on Tax Transparency & Exchange of Information
The OECD Global Forum published the 2026 Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request, covering 39 jurisdictions, including 14 assessed since December 2025. Particular progress has been made on beneficial ownership transparency and timeliness of responses. During 2023 and 2024, the monitored jurisdictions received more than 18,400 requests for information, with around 70% answered within 90 days; since 2009, EOIR has helped identify more than EUR 19 billion in additional tax revenues.
Fonte: CFE Tax Advisers Europe. Pubblicazione originale del 2026-06-30.