Newsletter CFE: bozza di relazione del Parlamento UE sulla rifusione della DAC, rapporto OCSE al G20 e peer review CbCR, dibattito FISC su tassazione dei patrimoni e 28° regime, riforme IVA e accise e parere CFE sul caso Nova Iberomoldes.
Parliament & Council Advance DAC Recast Legislative Process
The European Parliament's Economic and Monetary Affairs Committee has published a draft report on the proposed recast of the Directive on Administrative Cooperation. The rapporteur would remove the conditional DAC6 reporting exemption for multinational groups within Pillar Two scope and delete a provision limiting duplicative national reporting. Further amendments would add substance indicators for arrangements obscuring beneficial ownership, strengthen data safeguards and extend automatic exchange to capital gains on immovable property. Amendments are due by 12 November 2026.
In the Council, a Presidency compromise dated 8 October was discussed on 14 October, with renewed emphasis on foreseeable relevance. No agreement has been announced; talks continue on 26 and 27 October, and the Commission feedback period runs until 1 December 2026.
OECD Updates G20 on International Tax Cooperation & Publishes Corporate Tax Analysis & CbCR Peer Review Report
At the G20 meeting in Bangkok on 15 October, the OECD presented its report on international tax cooperation and growth. Around 65 jurisdictions are implementing the global minimum tax, and preliminary findings point to reduced profit shifting and higher revenues without significant harm to investment or employment. A public consultation on revisions to Chapter VII of the Transfer Pricing Guidelines on intra-group services will be held on 9 November 2026.
A separate OECD report looks at how corporate tax design, compliance costs and loss relief affect business entry and growth, warning that size-based reliefs can deter expansion. The ninth Country-by-Country Reporting peer review compilation, covering 142 jurisdictions, was also published.
FISC & National Parliaments Discuss Wealth Taxation & the EU's 28th Regime
On 12 October, MEPs and national MPs met in an Interparliamentary Committee Meeting organised by the FISC Subcommittee. The first session addressed the design and effectiveness of wealth taxes, including valuation, enforcement, avoidance and relocation risks. The second considered whether an optional common European business framework, the proposed 28th regime, could support cross-border expansion in the Single Market. The exchanges feed into FISC's work and do not represent an agreed parliamentary position.
Council Progresses Discussions on E-Commerce VAT & Excise Reforms
Council negotiations continue on e-commerce imports, VAT fraud prevention and tobacco taxation. On 20 October the Working Party on Tax Questions will examine VAT amendments linked to removing the €150 customs-duty threshold and to distance sales involving customs warehouses. It will also consider extending the optional reverse charge and the Quick Reaction Mechanism until 30 June 2030. On 26 October the High-Level Working Party will discuss these proposals and the tobacco tax package, aiming for agreement.
CFE Publishes Opinion Statement on Nova Iberomoldes (Case C-837/24)
CFE's ECJ Task Force has published an Opinion Statement on the Court of Justice judgment concerning real estate transfer taxes and the prohibition of indirect taxes on capital restructurings under Directive 2008/7/EC. The Court held that domestic requalification cannot exclude a transaction that qualifies as a protected restructuring under EU law. Anti-abuse measures must be proportionate and cannot rely on automatic requalification. The ruling may affect national rules treating share acquisitions in property-owning companies as real estate transfers.
Fonte: CFE Tax Advisers Europe