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Pubblication of the document "Considerations on Pillar Two and Befit" (link)

This document analyzes the impact and implications of Pillar Two (global minimum tax), adopted by the EU with the Directive of December 2022, and currently being implemented in several other countries. However, some major players such as the United States, China, and India have not joined. Recently, the new US administration has taken a strongly negative stance and has threatened retaliatory measures against "extraterritorial" taxes that affect US companies.

Although Pillar Two aims to combat tax arbitrage and increase revenues, its effectiveness may be limited by the potential shift of tax competition to other forms of taxation. Additionally, the high compliance costs could initially outweigh the additional tax revenues, which may fall short of expectations.

The document proposes a revision of BEFIT (Business in Europe: Framework for Income Taxation) to simplify the common tax base, bringing it as close as possible to the outcomes of Pillar Two, and thereby reducing compliance costs, in line with the decluttering strategy. A simplified and streamlined BEFIT, well-coordinated with Pillar Two, would drastically reduce administrative costs, create a level playing field, combat tax arbitrage, increase revenue, foster intra-EU integration, and improve the functioning of the internal market. Therefore, it would enhance the competitiveness of the European economy.

Finally, in the scenario of the implementation of Pillar Two and the establishment of BEFIT, the document argues for the opportunity to establish a European Tax Agency to strengthen administrative cooperation among member states, ensure efficient information exchange and consistent application of rules, and resolve disputes.