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Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union

This directive implements the OECD's Pillar Two rules, requiring multinational enterprise (MNE) and large-scale domestic groups with annual consolidated…

What Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union requires

This directive implements the OECD's Pillar Two rules, requiring multinational enterprise (MNE) and large-scale domestic groups with annual consolidated revenues of EUR 750 million or more to pay a minimum effective tax rate of 15% on their profits in each jurisdiction of operation (Article 2). It establishes the Income Inclusion Rule (IIR) and Undertaxed Profit Rule (UTPR) to collect a top-up tax when the effective tax rate in a jurisdiction falls below this minimum (Article 5).

Pillar: Banking & Global Finance · Authority: Council of the European Union · Version: 1.0.0 · Last updated:

Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022L2523

SHA-256 integrity: a9b35c665747503e1e584a45b0937e6c7c58d7e850ed334e138e436b9a10cc4e

Primary Citations — 8 traced to source

  • Council Directive (EU) 2022/2523, Article 2: Scope
  • Council Directive (EU) 2022/2523, Article 5: Application of the IIR and UTPR by Member States

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