The proposed directive aims at implementing the global tax reform agreement reached by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). The proposal sets out how the effective tax rate will be calculated, and includes rules on the allocation of top-up tax amongst jurisdictions.
GDV critizises the envisaged timeline. The rush in the legislative process presents difficulties for companies to implement the new rules given its complexitites and the fact that details of minimum taxation rules are still being developed at the OECD level. Furthermore, the proposed rules do not seem to be in line with the model rules published by the OECD. They run counter to national taxation systems for investment funds and may consequently lead to additional top-up tax in contradiction to the policy rationale of the minimum taxation system.