EU Tax Simplification Agenda: on 24 June 2026 the European Commission published the proposal for a Direct Tax Omnibus Directive and the DAC recast, a package estimated to reduce compliance costs for businesses by approximately €8 billion annually.
EU Tax Simplification Agenda: Direct Tax Omnibus
On 24 June 2026, the European Commission published a proposal for a Direct Tax Omnibus Directive as part of its wider Tax Simplification Package. The proposal seeks to modernise the EU direct tax acquis by simplifying existing legislation, reducing compliance burdens, improving legal certainty and supporting the competitiveness of the Internal Market. Together with the separate proposal to recast the Directive on Administrative Cooperation (DAC), the Commission estimates that the package could reduce compliance costs for businesses by approximately €8 billion annually.
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. According to the Commission, the reforms respond to increasing complexity arising from divergent implementation of existing directives, overlapping rules and more recent developments in international taxation, particularly the OECD Pillar Two global minimum tax framework.
Removal of Withholding Tax Barriers
A central element of the proposal is the abolition of withholding tax barriers on cross-border payments of dividends, interest and royalties between associated companies within the European Union. The Commission considers that existing procedures for obtaining withholding tax relief remain burdensome and continue to discourage cross-border investment despite previous reforms under the FASTER Directive. The proposal would also extend the scope of the Parent-Subsidiary Directive to pension institutions, allowing them to benefit from withholding tax exemptions on dividends received from other Member States.
New Common Standard for R&D Investment
The Omnibus introduces a common minimum standard for the tax treatment of investments in R&D-related tangible assets. Member States would be required to permit the immediate deduction of qualifying expenditure or allow taxpayers to deduct the expenditure over any of the following four tax periods. The proposal also adjusts the calculation of EBITDA under the Interest Limitation Rule to ensure that the new R&D allowance does not reduce a taxpayer's interest deductibility.
Simplification of the Anti-Tax Avoidance Directive
The proposal would simplify the Interest Limitation Rule by making the 30% EBITDA threshold and the €3 million de minimis threshold mandatory, introducing an inflation adjustment, excluding certain low-risk third-party borrowing, making the group escape rule and carry-forward mechanism mandatory, and introducing a safeguard where a taxpayer's EBITDA falls by 50% in a tax year. It would also reform the Controlled Foreign Company (CFC) rules by making Model A the only permitted approach across the EU; taxpayers within the scope of the OECD Pillar Two framework would generally be exempt from the CFC rules, subject to safeguards. In addition, the proposal removes imported hybrid mismatch rules from ATAD and updates the General Anti-Abuse Rule to ensure that it applies to all direct taxes, including withholding taxes and Pillar Two top-up taxes.
Cross-border Restructuring and Dispute Resolution
The proposal expands the scope of the Tax Merger Directive to cover all forms of corporate reorganisations recognised under EU company law, allowing a wider range of mergers, divisions, conversions and asset transfers to benefit from tax neutrality. It also introduces targeted amendments to the Dispute Resolution Mechanisms Directive to clarify procedural rules and improve access to dispute resolution. The proposal will now be submitted to the European Parliament for consultation before being considered by the Council under the special legislative procedure; as it is based on Article 115 TFEU, adoption will require unanimity.
EU Tax Simplification Agenda: DAC Recast
On 24 June 2026, the European Commission published a proposal to recast the Directive on Administrative Cooperation. The proposal consolidates the original Directive and its eight subsequent amendments into a single legislative text while introducing targeted changes affecting DAC1, DAC4, DAC6, DAC7 and DAC9, intended to simplify reporting obligations, improve legal certainty and reduce administrative burdens without lowering the existing level of protection against tax fraud, tax evasion and tax avoidance.
DAC6: Narrower Reporting for Cross-Border Arrangements
Multinational enterprise groups within the scope of the Pillar Two Directive would be excluded from DAC6 reporting where arrangements do not reduce taxation below the 15% global minimum effective tax rate. The proposal would also remove Category A hallmarks, clarify that only implementable arrangements are reportable, delete the concepts of "marketable" and "bespoke" arrangements, provide further guidance on the Main Benefit Test, extend the reporting deadline for intermediaries from 30 to 90 days and amend the legal professional privilege provisions to reflect recent CJEU judgments.
DAC7: Simplified Reporting by Digital Platform Operators
The proposal amends the reporting obligations for digital platform operators by removing the current activity threshold for sales of goods and increasing the monetary reporting threshold from EUR 2,000 to EUR 3,000, as the existing thresholds generate reporting of numerous low-value transactions presenting limited tax risk.
DAC4 and DAC9: Single Notification for Multinational Groups
The proposal would replace separate notification obligations under DAC4 Country-by-Country Reporting and DAC9 Top-up Tax Information Return reporting with a single notification for multinational enterprise groups, with a harmonised filing deadline, a common template and central filing by one group entity.
DAC1: Enhanced Exchange of Information
The definition of "available information" would be expanded to include information held by public authorities beyond tax administrations, enabling access to additional national registers, including certain anti-money laundering and real estate registers. Life insurance products would be removed from mandatory exchange and a new EU-wide taxpayer identification number (TIN) verification system would be introduced. The Commission estimates annual compliance cost savings of up to EUR 340 million for DAC6, approximately EUR 452 million for DAC7 and around EUR 270 million through the streamlining of DAC4 and DAC9 notifications. The proposal will now be considered by the European Parliament and by the Council under the special legislative procedure.
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 the latest evidence on the economic effects of the global minimum tax, focusing on outcomes such as 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. Registration is available on the OECD website.
CFE Issues Opinion Statement on Distinguishing Between Supplies of Goods & Services for VAT Purposes
CFE Tax Advisers Europe has published an Opinion Statement examining the distinction between supplies of goods and supplies of services under EU VAT law, a fundamental classification that determines the application of key VAT rules, including place of supply, exemptions, reduced rates and VAT liability. The Statement observes that the growth of digital business models, customised products and hybrid commercial arrangements has made the distinction increasingly difficult to apply in practice, resulting in divergent national interpretations, legal uncertainty and higher compliance costs. CFE calls on the European Commission and the VAT Committee to provide clearer guidance on common borderline cases and to further codify principles established by CJEU jurisprudence; in the longer term, legislative amendments may be needed to ensure the VAT framework reflects modern business models.
OECD Publishes Enhanced Monitoring Report on Tax Transparency & Exchange of Information
The OECD Global Forum has published the 2026 Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request, covering 39 jurisdictions that have completed the first round of the new enhanced monitoring process, including 14 jurisdictions assessed since December 2025. Across the 39 jurisdictions, 69 recommendations have been considered provisionally addressed, while 111 are in the process of being addressed, with particular progress on beneficial ownership transparency. During 2023 and 2024, the monitored jurisdictions received more than 18,400 requests for information, with around 70% answered within 90 days. Since 2009, the use of EOIR has helped identify more than EUR 19 billion in additional tax revenues.
Fonte: CFE Tax Advisers Europe. Pubblicazione originale del 2026-06-29.