Dočkáme se zrušení Pilíře 2?

At the end of June, representatives from the USA shared information that the rules of Pillar 2 would not apply to groups with a parent company in the USA and as a result, related retaliatory measures were removed from the proposed legislation, known as the One, Big, Beautiful Bill Act. A day later, the Group of Seven (G7) issued a statement supporting a side-by-side setup of the international tax system through the U.S. rules and the rules of Pillar 2. The G7 countries committed to continue collaborating to address potential risks of base erosion and profit shifting, based on accepted principles. From our perspective, the most interesting principle is one that fully excludes groups with a U.S. parent company from the core rule of Pillar 2 IIR and from the supplementary rule for low-taxed profit UTPR, concerning both their domestic and foreign profits.

At the beginning of July, information emerged in the press that in response to the U.S. exit German Federal Chancellor Merz called for a suspension of the application of Pillar 2 rules in the European Union. Shortly thereafter, however, the German Finance Minister supported the continuation of the application of the rules.

Ultimately, everything was further complicated by the European Commission. Two days ago, it presented the European Union's budget proposal for the years 2028 to 2034, which includes new sources of EU financing. One of these is the Corporate Resource for Europe (CORE), which represents an annual lump-sum contribution from companies other than small and medium-sized enterprises operating and selling in the EU with a net annual turnover of at least EUR 100 million. This source is expected to generate approximately EUR 6.8 billion annually on average.

In my view, the conclusion is clear. We will see.

Author:

Karel Hronek