On 12 September 2023, the European Commission published the Business in Europe: Framework for Taxation (BEFIT) proposal. Our BEFIT specialists provided feedback on this proposal. The submission with our feedback provides both comments and recommendations with the aim to enhance the BEFIT Proposal.

BEFIT is a common corporate tax framework for large groups within the EU. Our comments to the BEFIT Proposal have been divided into four parts and focus on some critical issues that we identified:

  1. Firstly, we focus on some general issues that may hamper achieving the objectives.
  2. Secondly, we address more technical issues regarding specific provisions in relation to scope and administrative procedure.
  3. Thirdly, we discuss the transfer pricing clauses.
  4. Finally, we elaborate on the negative impact that the interaction with the Pillar Two rules might have. Various recommendations have been proposed as well.

The document submitted to the European Commission was prepared by Nicolas Lippens, Marieke Bakker, Linda Brosens, Rogier Sterk, Carlijne Brinkers and Lisanne Bergwerff.

Reading our feedback will give you more feeling for the direction the EU is heading towards and the various issues that in our view still need to be addressed. Should you wish to get more background information on this topic, please contact one of our BEFIT specialists.

To read the document in full, please click on the download button provided below.


Loyens & Loeff submits feedback on BEFIT Proposal

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.