On 19 September 2023, the EU Commission opened a consultation on its BEFIT Directive, which was published the previous week. BEFIT is the acronym for Business in Europe: Framework for Income Taxation. The initiative, widely considered to replace the EU Commission’s Consolidated Common Corporate Tax Base, will aim to introduce a common set of rules for groups of companies and head offices, based in the EU, to determine their taxable base. The BEFIT proposal could also apply to non-EU-headquartered groups.
On 24 October 2022, the Netherlands published an extensive draft proposal, including detailed commentary, for the implementation of the GloBE Model Rules in Dutch tax legislation. The Dutch Pillar 2 Proposal is presented as a stand-alone legislative act referred to as the “Minimum Tax Act 2024”, which would exist separate from the Dutch corporate income tax act. The Minimum Tax Act 2024 is largely based on the EU Pillar 2 Directive that was published on 22 December 2021 and further updated in subsequent months.