European Commission presses 11 Member States on failing to implement Beneficial Ownership transparency rules
On 25 September 2025, the European Commission launched infringement procedures against Belgium, Denmark, Germany, Estonia, Greece, Italy, Cyprus, Croatia, Poland, Slovakia, and Sweden for failing to fully transpose the 6th Anti-Money Laundering (AML) Directive by the first deadline of 10 July 2025. The directive requires Member States to guarantee comprehensive access to beneficial ownership information for legal entities, trusts and similar arrangements, including for those with a legitimate interest, in order to combat money laundering and terrorist financing. While the main provisions must be transposed by 10 July 2027 — when the 4th AML Directive as amended by the 5th will be repealed — key obligations on transparency had to be met earlier. To date, 11 Member States have not notified complete measures. The Commission stresses that full implementation is essential to protect financial systems from abuse and to maintain consistent standards across the Union. The concerned countries now have two months to comply and notify their measures, or the Commission may escalate the case by issuing a reasoned opinion.
European Commission publishes ViDA implementation strategy
On 24 September 2025, the European Commission published its implementation strategy for the VAT in the Digital Age (ViDA) package, presenting actions to support businesses and Member States with the practical implementation of the EU’s VAT framework updates. The ViDA package introduces new digital reporting requirements, addresses challenges in the platform economy sector with specific VAT adaptations and develops a more streamlined single VAT registration process. ViDA is a complex package of measures, with five main different implementation dates for its various elements, alongside a number of options for Member States. In addition, the preparation for implementation covers legislative, non-legislative and IT elements, each of which are inter-dependent on each other. For this reason, the implementation strategy provides a clear roadmap with key actions points and dates, ensuring coordinated and effective application, and raises several specific points of attention. It also points out the importance of the integration of ViDA with other legislative efforts, as misalignment could create complexity or limit the full realisation of benefits.
Experts and MEPs discuss tax implications of US policies
On 23 September 2025, the European Parliament’s FISC Subcommittee held a hearing on the tax implications of US policies under the Trump administration, with contributions from experts representing the European Commission, business, academia, and the EU Tax Observatory. A key focus was the debated “side-by-side” approach, with Benjamin Angel from the European Commission’s DG TAXUD arguing that a safe-harbour mechanism would be the best option, since full equivalence with Pillar Two is impossible, and such a solution would not require amending the EU Directive. He cautioned, however, that this would still demand rapid changes to national legislation. Benjamin Angel also stressed that several jurisdictions are calling for an agreement that is not US-centric but based on clear access criteria, and that for the EU any deal must include strong safeguards. The representative of BusinessEurope warned that without global adoption, OECD rules risk undermining EU competitiveness, while the EU Tax Observatory’s representative opposed aligning with the US model. MEPs further questioned the impact of US tax and tariff policies on international negotiations and EU businesses, ahead of their late-October delegation visit to Washington and New York. The hearing can be rewatched here.
MEPs adopt their position on the BEFIT proposal
On 24 September 2025, the ECON committee of the European Parliament adopted its position on the Business in Europe: Framework for Income Taxation (BEFIT) proposal, establishing a common way of calculating the tax base of multinationals operating in the EU. The non-binding opinion, drafted by MEP Evelyn Regner (S&D, Austria), introduces a “significant economic presence” clause, deeming firms with over €1 million in revenues in a Member State as permanently established there. MEPs also propose a royalties limitation rule to curb profit shifting, requiring payments to low-tax group entities (below 9%) to be added back to taxable income unless backed by real economic activity. Further measures target passive income shifted to low-tax foreign subsidiaries lacking substance, while an additional amendment allows accelerated tax write-offs for assets supporting EU climate, social, digital, or defence priorities. The text will now move to a plenary vote in November, before being transmitted to Member States.
Experts and MEPs discuss the future of the Single Market for services
On 24 September 2025, MEPs from the IMCO Committee of the European Parliament discussed with experts from the European Commission, national authorities, consumer groups and industry the strengthening of the Single Market for services. The hearing assessed current barriers and explored actions to improve outcomes for consumers and businesses across the EU, in the context of the Commission's recent Single Market Strategy. Mary Veronica Tovšak Pleterski from the European Commission’s DG GROW specifically mentioned two priority barriers the Commission wants to work on: the slow recognition of professional qualifications and diverging and restricting national regulations, with solutions such as greater digitalisation and extended automatic recognition. The Commission also wants to facilitate the provision of pan-EU services by allowing a provider authorised in one Member State to deliver the same service in another Member State and will look first at the services which are based on EU law for certification and authorisation. On enforcement, she stressed that infringements are only the tip of the iceberg and called for better use of notification mechanisms and a collaborative approach to prevention. The hearing can be rewatched here. A study requested by the IMCO Committee on the “Single Market Competitiveness: Advancing Cross-Border Trade in Services” has also been published.
OECD 2025 CbCR peer review reports
On 23 September 2025, the OECD released the eighth annual peer review of the BEPS Action 13 minimum standard on Country-by-Country (CbC) reporting, covering 142 jurisdictions. CbC reporting obliges large multinational groups to disclose key financial and operational data for each jurisdiction, helping tax administrations better assess risks and address profit shifting. For each jurisdiction, the review covers the domestic legal and administrative framework, the exchange of information framework and measures in place to ensure the confidentiality and appropriate use of CbC reports. The review found that over 120 jurisdictions have a legal framework in place, 22 were urged to finalise theirs and 27 received recommendations for improvements. On information exchange, 101 jurisdictions have competent authority agreements in force. In addition, 89 jurisdictions demonstrated measures to ensure the appropriate use of CbC reports. Some members, including the Cook Islands, Saint Kitts and Nevis, and Samoa, were not included in this review due to late membership or opting out. The peer review is an annual process to track implementation and progress globally.
Albania signs Pillar Two Subject to Tax Rule
Albania has signed the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) at a ceremony in Paris, making Albania the 10th jurisdiction to join, the OECD announced in a release on 23 September 2025. The STTR applies to certain cross-border intragroup payments taxed below 9% in the recipient’s jurisdiction, allowing the source country to impose additional tax up to that minimum. Inclusive Framework members with nominal rates under 9% have committed to including the STTR in treaties with developing countries upon request. The STTR MLI enables swift implementation of this rule across existing bilateral tax agreements without renegotiation. Full texts, background and signatory positions are available at https://oe.cd/sttr-mli.
