First announced: Council Directive (EU) 2022/2523 adopted 14 December 2022 and published in Official Journal 22 Dec 2022.
Submitted by: NYBACS Compliance Desk
The EU adopted a Pillar Two Directive (Council Directive 2022/2523) on 14 Dec 2022 implementing a 15% global minimum tax for qualifying groups.
Member States must transpose the Directive into national law — timing varies by country.
Multinationals should quantify top-up tax exposure and centralise tax data.
What changed: The EU passed Council Directive (EU) 2022/2523 on 14 December 2022 to implement the OECD Pillar Two minimum taxation rules at EU level (15% minimum ETR via IIR / UTPR / QDMTT mechanics). The Directive sets the legal framework that compels Member States to adopt domestic measures so a common minimum tax can be applied across the EU.
Who’s affected: Multinational groups with consolidated revenue above the €750 million threshold and groups with significant EU footprints.
Immediate actions
- Run a cross-border Pillar Two impact assessment (allocate by jurisdiction and compute provisional ETRs).
- Assemble country-by-country data and documentation to support GloBE calculations.
- Discuss with auditors about potential top-up tax provisioning and disclosure timelines.
Practical notes: Transposition timelines and the exact mechanics (IIR vs QDMTT vs UTPR sequencing) can vary by Member State — track national draft bills closely and update your global tax model accordingly.
