EU agrees pillar two global minimum tax rate

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

EU agrees pillar two global minimum tax rate

EU - pillar two.jpg

Hungary lifts its veto as the EU takes the lead on applying the OECD’s pillar two agreement.

EU member states achieved a historic breakthrough yesterday, December 12, by agreeing to implement the OECD’s global corporate minimum tax rate of 15% across the bloc.

The decision to adopt the minimum tax rate, known as pillar two, came after the Hungarian government dropped the last remaining objection to applying the measure in the EU.

EU ambassadors released some post-COVID recovery funds, which had previously been blocked due to a rule of law dispute between Hungary and the bloc, in exchange for Budapest lifting its veto to the tax floor rate.

Zbyněk Stanjura, finance minister of the Czech Republic, which holds the rotating presidency of the Council of the EU, welcomed the agreement as a clear and strong message to businesses on tax.

“The largest groups of corporations, multinational or domestic, will need to pay a corporate tax that cannot be lower than 15% globally,” he said in a statement.

The landmark two-pillar solution, which was reached at the OECD Inclusive Framework by 137 countries in October 2021, represents the most wide-reaching attempt to reduce profit-shifting by global corporations.

Pillar two aims to ensure that large multinationals with revenues of at least €750 million ($790 million) pay an international minimum effective tax rate of 15% in all the countries in which they operate.

Meanwhile, pillar one would overhaul international taxing rights to ensure that multinationals declare profits and pay tax in the jurisdictions where they do business. The measure would apply to large multinationals with revenues exceeding €20 billion ($21.1 billion).

The EU’s minimum tax rate move is seen as crucial to saving pillar two after the measure had gone cold on both sides of the Atlantic due to fierce political and business resistance.

European ambassadors have now set the ball rolling on applying the tax floor rate by advising the Council of Ministers to formally adopt the pillar two directive. The EU law is expected to be transposed into member states’ domestic rules by the end of 2023.

more across site & shared bottom lb ros

More from across our site

As AI becomes increasingly intuitive and idiot-proof, its tax applicability is becoming impossible to overstate
New data on public CbCR showed uneven adoption, as Singapore advanced pillar two compliance and firms expanded their tax capabilities
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks
The EU agreed new cooperative and investigative measures to tackle VAT fraud, while Hungary faced legal action and Lavez Coutinho expanded its indirect tax team
The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates
CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard
Gift this article