Jurisdictions implementing the Global Minimum Tax from 2024 have agreed a common understanding intended to preserve the administrative and compliance benefits of the central filing mechanism for the GloBE Information Return (GIR). The agreement addresses concerns that some jurisdictions may not have
BRUSSELS | 25 MAY 2026
OECD Releases Common Understanding & Updated Guidance on Global Minimum Tax Implementation
Jurisdictions implementing the Global Minimum Tax from 2024 have agreed a common understanding intended to preserve the administrative and compliance benefits of the central filing mechanism for the GloBE Information Return (GIR). The agreement addresses concerns that some jurisdictions may not have fully operational GIR filing portals or activated exchange relationships in place ahead of the first GIR filing deadline on 30 June 2026. Under the central filing and exchange framework, multinational enterprise groups in scope of the global minimum tax are relieved from locally filing a GIR in each jurisdiction where they operate where the GIR is centrally filed in the jurisdiction of the Ultimate Parent Entity (UPE) or a Designated Filing Entity (DFE) and the information is exchanged with local jurisdictions under the agreed exchange framework. Participating jurisdictions to the common understanding will publish a list of jurisdictions expected to have fully operational GIR filing portals in place by 31 May 2026 and will use mechanisms available under their respective domestic laws to waive penalties or suspend enforcement of local GIR filing obligations before the relevant GIR exchange deadline where a GIR has been centrally filed in one of the jurisdictions identified in the published list. The OECD noted that 37 jurisdictions have implemented a Qualified Income Inclusion Rule (QIIR) and/or a Qualified Domestic Minimum Top-up Tax (QDMTT) applicable to in-scope MNE Groups for the 2024 fiscal year. While almost all jurisdictions are expected to have operational filing portals in place before the filing deadline, some jurisdictions may only formally activate exchange relationships later in 2026. The common understanding agreement seeks to ensure that in-scope MNE groups are not adversely affected because exchange relationships are not fully activated by the filing deadline. Jurisdictions may nevertheless take enforcement action where a centrally filed GIR is not exchanged with the relevant jurisdiction by the applicable exchange deadline. The OECD/G20 Inclusive Framework has also released further administrative guidance on the application of the Transitional Undertaxed Profits Rule (UTPR) Safe Harbour and updated the Central Record for purposes of the Global Minimum Tax. The guidance addresses an unintended gap affecting MNE Groups with 52–53-week fiscal years that begin on or before 31 December 2025 but end after 31 December 2026. Under the previous wording of the Transitional UTPR Safe Harbour, such groups risked falling outside both the transitional relief and the later Side-by-Side (SbS) or UPE Safe Harbour regimes. The guidance clarifies that the Transitional UTPR Safe Harbour will continue to apply to fiscal years beginning on or before 31 December 2025 and ending on or before 3 January 2027, thereby ensuring continued eligibility for affected MNE Groups until the SbS Safe Harbour or UPE Safe Harbour becomes applicable. The OECD will amend the Commentary to reflect the revised definition of the “Transition Period”. The Central Record for Purposes of the Global Minimum Tax sets out jurisdictions whose minimum tax legislation has completed the transitional qualification mechanism process and is treated as qualified for purposes of the Pillar Two rule order. The update now reflects that the Bahamas, Kenya, Kuwait and Oman have completed the qualification process in respect of their domestic minimum top-up taxes. As a result, the Central Record now shows that 44 jurisdictions have completed the qualification process for their Income Inclusion Rules (IIRs), while 50 jurisdictions have completed the process for their DMTTs and QDMTT Safe Harbour status. The OECD further reiterated that the absence of legislation from the Central Record does not necessarily indicate that the legislation is not qualified, but rather that the transitional qualification mechanism has not yet been initiated or completed for that legislation.
EU Commission Publishes 2026 Work Programme for VAT in the Digital Age Implementation
The European Commission published the 2026 work programme for the implementation of the VAT in the Digital Age (ViDA) package on 20 May 2026, setting out the legislative, technical and administrative measures that will support the phased rollout of the ViDA reforms between 2025 and 2035. The programme outlines a series of implementing regulations, explanatory notes, IT developments and stakeholder consultations intended to facilitate the introduction of the new VAT reporting and registration framework across the European Union. Key milestones scheduled for 2026 include the expected publication of the EU standard for e-invoicing in Q2 2026, alongside the first amendment to Implementing Regulation (EU) 2020/194 concerning the Single VAT Registration regime. The Commission also plans to adopt the implementing regulation on the Digital Reporting Requirements in Q3 2026. The regulation will establish the common electronic message format through which taxable persons will provide transaction data to Member States. During the same period, the first implementing regulation concerning the central VAT Information Exchange System is expected to be adopted, together with the finalisation of the functional and technical specifications for changes to the One-Stop Shop (OSS) system applying from 1 July 2028. The work programme also sets out developments relating to the Import One-Stop Shop (IOSS), including the testing and deployment of a fast-track solution designed to secure IOSS numbers during 2026. The Commission confirmed that a “Per-transaction Token” model has been selected for pilot testing as part of the securitisation process. Further implementing measures expected during 2026 include amendments to the OSS system for changes applying from 1 January 2027 and explanatory notes covering the DRR, platform economy measures and VAT e-commerce rules. In parallel, the Commission plans to continue formal and informal consultations with Member States and business stakeholders throughout 2026 via meetings of the Standing Committee on Administrative Cooperation, the Group on the Future of VAT, the VAT Expert Group, Fiscalis project groups and the Standing Committee on Information Technology. Additional implementing measures are expected in 2027, including further regulations concerning the central VIES framework and technical requirements relating to the Standard Audit File for OSS special schemes. The Commission confirmed that testing of the central VIES with Member States is expected to take place between Q1 2029 and Q3 2030, ahead of the entry into force of the DRR provisions on 1 July 2030, when the central VIES is scheduled to become operational.
AMLA Publishes Direct Supervision Reporting Framework & FIU Cooperation Standards
The EU Anti-Money Laundering Authority has published a reporting package for the identification of “provisionally eligible obliged entities” that may fall under AMLA’s direct supervision from 2028. The package forms part of preparations for AMLA’s first selection exercise in 2027 and includes a standardised reporting template together with interpretative guidance for national supervisors and reporting entities. Under Article 12(1) of the AML Regulation, AMLA will directly supervise certain high-risk credit institutions, financial institutions and groups operating in at least six Member States, including through establishments or cross-border services. The guidance clarifies reporting obligations relating to group structures, establishments, customer activity and supervisory arrangements, including the designation of a single reporting entity for group submissions. Separately, AMLA has launched consultations on three draft Implementing Technical Standards concerning cooperation between Financial Intelligence Units (FIUs), AMLA and the European Public Prosecutor’s Office (EPPO). Two of the draft ITS establish harmonised reporting formats for transmitting information to the EPPO in cases involving suspected offences affecting the EU’s financial interests, while a third introduces standard templates for information exchanges between FIUs through FIU.net. The measures are intended to improve the consistency, completeness and automation of cross-border AML/CFT information sharing and supervisory cooperation across the EU. Public hearings on the draft ITS will take place on 27 May 2026, while AMLA will host a webinar on 10 June 2026 concerning the reporting template for entities potentially subject to direct supervision. These developments are expected to feature at AMLA’s first annual conference, to be held in Frankfurt on 9 June 2026, bringing together representatives from supervisory authorities, FIUs, EU institutions, law enforcement bodies and the private sector to discuss developments in the EU AML/CFT framework.
FISC to Examine Future Direction of EU Corporate Tax Policy
The European Parliament Subcommittee on Tax Matters, FISC, willl next meet on 2 June 2026. At the meeting, FISC will hold a public hearing examining the role of the reverse charge mechanism in combating VAT fraud within the EU VAT system, with a particular focus on Missing Trader Intra-Community (MTIC) fraud. The discussion will assess the operation of the mechanism under Articles 199a and 199b of the VAT Directive, which are currently due to expire on 31 December 2026, including its effectiveness, possible design improvements, and whether the measures should be extended beyond the current deadline. The hearing will also consider broader implications for the EU VAT framework and ongoing efforts to strengthen tax compliance and tackle cross-border fraud. The FISC Subcommittee will also discuss a draft own-initiative report on the EU’s approach to corporate tax policy in a changing international environment. The report examines the implications of the OECD/G20 Inclusive Framework agreement reached at the end of 2025 on a “Side-by-Side approach” to minimum taxation. It highlights continuing challenges for the EU corporate tax framework despite the agreement, including concerns regarding EU competitiveness and the need for simplification and greater legal clarity. The draft report also calls on the European Commission and Member States to strengthen international cooperation to address base erosion and profit shifting practices and notes the continuing need for an international solution for the taxation of the digitalised economy. The FISC agenda also includes further consideration of amendments to the draft report on the feasibility of a “28th tax regime” to support EU competitiveness, prepared by rapporteur Ľudovít Ódor (Renew), followed by an in camera Coordinators’ meeting.
Council of the EU and EU Parliament Reach Provisional Agreement on Tariff Measures Under EU-US Joint Statement
On 20 May 2026, the Council of the European Union and the European Parliament reached a provisional agreement on two regulations implementing the tariff-related commitments contained in the EU-US Joint Statement of 21 August 2025. The measures are intended to support a more stable and predictable transatlantic trade relationship while maintaining safeguards to protect EU economic interests. The first regulation removes the remaining EU customs duties on US industrial goods and introduces preferential market access through tariff rate quotas and reduced tariffs for certain US seafood products and non-sensitive agricultural goods. The second regulation extends the suspension of customs duties on imports of lobster, including processed lobster products, with retroactive effect from 1 August 2025. The provisional agreement strengthens the European Commission’s powers to respond to adverse market effects through a dedicated safeguard mechanism. Under the mechanism, the Commission may investigate whether increased imports from the United States have caused or threaten to cause serious injury to EU producers. Investigations may be initiated following substantiated requests from at least three Member States, EU industry representatives or trade unions, or on the Commission’s own initiative. Where sufficient evidence exists, the Commission may suspend the application of the regulations in whole or in part. The agreement also reinforces the conditions under which the Commission may suspend the tariff concessions through implementing acts. Suspension may occur where the United States fails to comply with the commitments of the Joint Statement, undermines its objectives, or disrupts EU-US trade and investment relations. In addition, the Commission may suspend concessions relating to steel and aluminium products if the United States continues to apply tariffs exceeding 15% on EU steel and aluminium derivative products after 31 December 2026. Both regulations are subject to a sunset clause and will cease to apply at the end of 2029 unless extended through further legislative action. The agreement also establishes regular monitoring requirements. Six months after entry into force, and every three months thereafter, the Commission must report on changes in trade volumes and values relating to covered US exports to the European Union. A broader assessment examining impacts on EU-US trade flows, tariff revenues and SMEs must also be prepared six months before the regulations expire. The provisional agreement is subject to technical finalisation and must still be formally endorsed and adopted by both the Council and the European Parliament before publication in the Official Journal and entry into force.
The selection of the remitted material has been prepared by: Dr. Aleksandar Ivanovski & Brodie McIntosh
Fonte: CFE Tax Advisers Europe. Pubblicazione originale del 2026-05-25.