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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 establishes a global minimum tax regime requiring multinational enterprise (MNE) groups and large-scale domestic groups with 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 establishes a global minimum tax regime requiring multinational enterprise (MNE) groups and large-scale domestic groups with consolidated revenue of at least EUR 750 000 000 to pay a minimum effective tax rate of 15% in each jurisdiction where they operate, applying the Income Inclusion Rule (IIR) and Undertaxed Profit Rule (UTPR) as set out in Article 3 and Article 4.

Pillar: Tax & Transfer Pricing · Authority: Council of the European Union · Version: 1.0.1 · Last updated:

Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022L2523

SHA-256 integrity: 7b3e99a8e6520de1d4162dbf3d5ea44fb84381a0ab07a570620ff168b8ff72d1

Primary Citations — 5 traced to source

  • Council Directive (EU) 2022/2523, Article 1(1) - Scope: applies to MNE groups and large-scale domestic groups with consolidated revenue of at least EUR 750 000 000
  • Council Directive (EU) 2022/2523, Article 3 - Income Inclusion Rule (IIR): parent entity in a Member State must apply IIR to low-taxed entities

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