ARTICLE · 21 DECEMBER 2022

EU Member States Reach Agreement On Minimum Tax Directive (Pillar Two)

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On 12 December 2022, the EU Council announced that EU Member States reached political agreement to implement the minimum tax component (Pillar Two) of the OECD's global international tax reform initiative.

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John Ellul Sullivan

Lisa Zarb Mizzi

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On 12 December 2022, the EU Council announced that EU Member States reached political agreement to implement the minimum tax component (Pillar Two) of the OECD's global international tax reform initiative.

Pillar Two introduces a global minimum tax, agreed at 15% by the Inclusive Framework Members, including Malta , calculated based on a specific rule set. It applies to groups with combined revenues of more than €750 million a year.

According to an EU Council press release, the Committee of Permanent Representatives (COREPER) reached the required unanimous support, and the ambassadors of EU Member States advised the Council to adopt the Pillar Two minimum tax directive.

The proposed text of the EU Directive (compromise text here) is subject to formal adoption through a written procedure. The deadline for the procedure to be finalized is expected to be 14 December 2022. The EU proposed Directive generally mirrors the OECD model rules on Pillar Two released in

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