EU Commission Issues Draft Directives On Substance Requirements And Minimum Taxation

On 22 December 2021, the EU Commission issued two major draft directives that are expected to have a significant impact on EU corporate taxpayers:

• a proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU (the "Unshell Proposal"); and
• a proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union (the "Pillar II Proposal") [ click here for quick access to this section].

The Unshell Proposal would have to be implemented and applied by Member States from 1 January 2024. The Pillar II Proposal would have to be implemented and largely applied by Member States from 1 January 2023.