Commission Communication outlines tax enforcement priorities in the EU Single Market rulebook
On 28 April 2026, the European Commission published its Communication, “A Simpler, Clearer and Better Enforced EU Rulebook”, outlining measures to improve the design, implementation and enforcement of EU law . From a taxation perspective, the Communication and its annexes identify company law digitalisation and cross-border mobility, as well as savings and investments, as priority areas where enforcement will be stepped up. In particular, Annex II highlights shortcomings in the application of EU tax rules linked to cross-border company mobility, noting that Member States continue to apply divergent tax treatment to dividend and payment streams and do not always ensure tax-neutral treatment of mergers, divisions and restructurings, pointing to potential misapplication of the Parent-Subsidiary Directive and the Tax Merger Directive. The Commission also flags concerns regarding territorial restrictions in national tax incentives, such as those linked to research, development or employment, which may create barriers to the Single Market. In parallel, Annex I sets out the “Regulatory Deep Cleaning” action plan, under which taxation is identified as a priority area, including through a forthcoming tax omnibus initiative aimed at simplifying direct tax directives and reducing compliance burdens and legal uncertainty. Overall, the Communication signals increased scrutiny of Member States’ tax rules and a stronger focus on ensuring consistent application of EU tax law across the Single Market.
European Commission’s April tax infringement decisions
On 24 April 2026, the European Commission published its monthly package of infringement decisions. In the area of taxation, the Commission sent a reasoned opinion to Spain for breaching the free movement of capital under Article 63 TFEU in relation to the taxation of non-resident taxpayers’ dwellings. Under Spanish rules, deemed income from real estate is generally taxed at 2% of the cadastral value, while properties used as the habitual residence of resident taxpayers are exempt. This exemption does not apply to non-resident taxpayers, which the Commission considers discriminatory. Spain now has two months to respond and take the necessary measures, failing which the case may be referred to the Court of Justice of the European Union. In addition, the Commission decided to refer Hungary to the Court of Justice of the European Union for failing to bring its retail tax regime into line with the freedom of establishment under Articles 49 and 54 TFEU. According to the Commission, the regime imposes higher progressive tax rates on foreign-controlled retail companies, while domestic retailers operating through franchise systems are not subject to equivalent rates, as their turnover is not consolidated for tax purposes. The Commission considers that this differential treatment restricts the ability of foreign-controlled companies to organise their activities in Hungary, thereby constituting a restriction on the freedom of establishment.
European Commission proposes update to EU autonomous tariff quotas for certain products
On 27 April 2026, the European Commission published a proposal for a Council Regulation amending Regulation (EU) 2021/2283 on autonomous tariff quotas for certain agricultural and industrial products. Autonomous tariff quotas allow the import of specific goods at reduced or zero duty rates where EU production is insufficient to meet demand. The proposal introduces four new tariff quotas for products not currently covered, adjusts the description or volume of several existing quotas to better reflect market needs, and removes two quotas that are no longer considered to be in the Union’s economic interest. According to the Commission, these changes aim to ensure an adequate supply of goods for EU industry under favourable conditions without disrupting the internal market. The proposal also provides for the publication of a consolidated version of the Annex to the Regulation for reasons of clarity. The amended quotas are expected to apply from 1 July 2026.
Commission opens public consultation on the 28th regime proposal for innovative companies
On 30 April 2026, the European Commission opened a public consultation on its proposal for a Regulation on the 28th regime, that it presented on 18 March 2026. The initiative is aimed at providing companies, in particular innovative ones, with a single harmonised set of rules to operate more easily across the Single Market. While the proposal primarily establishes a new corporate legal framework supported by digital tools and procedures, it also includes a limited tax-related provision. In particular, Article 79 addresses the tax treatment of employee stock options issued under the EU-ESO, providing that the taxable event arises only upon disposal of the underlying shares, rather than at grant, vesting or exercise. It further requires Member States to ensure that such instruments receive tax treatment no less favourable than comparable national schemes. The proposal clarifies that these provisions are not intended to harmonise taxation, but rather support the broader objectives of the framework. The consultation is open until 25 June 2026, with feedback expected to inform the ongoing legislative process.
European Commission sets out temporary State aid framework with tax and energy taxation measures
On 29 April 2026, the European Commission adopted a Communication establishing a Temporary State Aid Framework to support sectors affected by the economic impact of the Middle East crisis, with measures applicable until 31 December 2026. From a taxation perspective, the framework allows Member States to grant aid in the form of tax and payment advantages, including through reductions in energy taxation in line with the Energy Taxation Directive, subject to existing EU rules. It also enables simplified support schemes, including compensation of up to 70 percent of additional fuel and fertiliser costs for sectors such as agriculture, fisheries and transport. In parallel, the framework introduces temporary flexibility in existing State aid rules, including higher aid intensities for electricity costs, while maintaining safeguards to limit distortions of competition. The Communication sets out the conditions under which such aid will be assessed under Article 107(3)(c) TFEU, emphasising its targeted, proportionate and temporary nature.
MEPs publish draft report on EU corporate tax policy in changing international environment
On 27 April 2026, the European Parliament’s Committee on Economic and Monetary Affairs (ECON) published a draft own-initiative report on EU corporate tax policy in a changing international environment. The draft report, prepared by rapporteur Kinga Kollár (EPP, Hungary), focuses on the interaction between the OECD Pillar Two framework, the United States minimum tax regime referred to as NCTI, and the OECD’s Side-by-Side Package. It highlights structural differences between the US regime and Pillar Two, including in scope, tax base, blending approach and effective tax rate, and raises concerns that the proposed safe harbours could lead to an uneven application of the rules, potentially exempting US-headquartered groups while EU-parented groups remain fully subject to the EU Directive. The report calls on the European Commission to assess these potential imbalances and consider appropriate responses. It also supports ongoing tax simplification efforts through the forthcoming Tax Omnibus and calls for a review of overlapping EU tax rules, including provisions under ATAD, the Parent-Subsidiary Directive, the Merger Directive, the Country-by-Country Reporting Directive and the DAC framework. In addition, the report invites the Commission to reassess the BEFIT proposal in light of possible interactions with Pillar Two. On digital taxation, it emphasises the importance of a coordinated global approach and cautions against unilateral measures. The deadline for tabling amendments is 9 June 2026.
OECD releases implementation toolkit to support global minimum tax rollout
On 30 April 2026, the OECD published a new “Global Minimum Tax Implementation Toolkit” to support tax administrations in the consistent and co-ordinated application of the global minimum tax (GMT) framework. Developed by the OECD Forum on Tax Administration, the toolkit provides practical guidance across the full implementation process, from initial impact assessments and legislative design to compliance procedures and the administration of top-up taxes. It sets out a structured roadmap for jurisdictions, including identifying in-scope multinational enterprise groups, estimating potential revenues, establishing legal frameworks, and designing operational and IT systems to support compliance. The toolkit also emphasises the importance of international co-operation, notably through the exchange of information mechanisms such as the GloBE Information Return, and highlights shared challenges faced by jurisdictions transitioning from rulemaking to implementation. Drawing on the experience of early adopters and ongoing work within the OECD/G20 Inclusive Framework on BEPS, the guidance promotes the use of common approaches and best practices to enhance tax certainty, reduce administrative burdens, and ensure consistent application of the rules across jurisdictions. The toolkit is intended as a practical reference for tax administrations and does not modify the OECD’s agreed standards for the implementation of the global minimum tax.
OECD publishes practical guide on investment tax incentives
On 27 April 2026, the OECD published “A Practical Guide to Investment Tax Incentives”, a guide that provides practical guidance to policymakers on the design and implementation of tax incentives aimed at attracting investment. The report sets out a structured policy framework covering the full lifecycle of tax incentives, including the identification of policy objectives, the selection and design of appropriate instruments, and their implementation, monitoring and evaluation. It notes that expenditure-based incentives, such as tax credits, allowances and accelerated depreciation, provide tax relief in proportion to investment expenditure, whereas income-based incentives, including tax exemptions, provide relief linked to profits and may therefore be less closely aligned with investment decisions. The OECD highlights the importance of clearly defined objectives, well-targeted eligibility criteria and simple, transparent design features, alongside predictable and rules-based administrative processes. It also underlines the need for ex-ante analysis and regular monitoring and evaluation, supported by adequate data collection, to assess whether incentives achieve their intended objectives. Overall, the report emphasises that tax incentives should be carefully designed and regularly reviewed to ensure they are effective, proportionate and consistent with broader tax policy frameworks.
International Tax Observatory research highlights uneven tax transparency and offshore wealth risks for developing countries
On 27 April 2026, the International Tax Observatory published a research note on offshore wealth and tax transparency, examining the implications of uneven global transparency frameworks for developing countries. The note finds that global offshore financial wealth has remained broadly stable at around 7% of total household financial wealth in recent decades, despite progress in international tax transparency. While high-income countries benefit from extensive coverage through automatic exchange of information mechanisms such as the OECD’s Common Reporting Standard (CRS) and the U.S. Foreign Account Tax Compliance Act (FATCA), participation remains uneven across jurisdictions. In particular, many lower-income countries do not participate in the CRS or lack reciprocal FATCA agreements, resulting in significant gaps in the coverage of offshore assets. The analysis shows that a substantial share of offshore wealth linked to developing regions remains outside information exchange frameworks, limiting the ability of tax authorities to address offshore tax evasion risks. The note concludes that improving global tax transparency requires enhanced international cooperation, capacity-building support and more comprehensive information sharing.
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