Business in Europe: Framework for Income Taxation (BEFIT)

6.11.2025 A10-0194/82

Amendment 82

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 1 a (new)

Text proposed by the Commission

Amendment

(1 a) In 1975, the Commission tabled a proposal to minimise the differences between Member States' corporate tax rates. Under the proposal, Member States could still choose their own corporate tax rate, but that rate could “not be lower than 45 % nor higher than 55 %”. Due to a lack of support from Member States, the proposal was withdrawn.

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6.11.2025 A10-0194/83

Amendment 83

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 1 b (new)

Text proposed by the Commission

Amendment

(1 b) In 2016, the Commission tabled an altered 'rebooted' proposal for a common corporate tax base (CCCTB). A common European corporate tax base would serve as a single rulebook on how companies should calculate their overall profit in the Union. After calculating a common tax base, a company active in more than one Member State could add up all the profits and losses of its entities in the different Member States to work out its total net profit or loss for the entire Union (consolidation). The company's taxable profits would then be allocated between the respective company entities, using an apportionment formula (formulary apportionment), with the profits being divided on the basis of three equally weighted factors (labour, tangible assets and sales). Each Member State would then tax the allocated shares of the company's profits at its own national corporate tax rate. The 2016 CCCTB proposal eventually met the same fate as its 2011 predecessor. The Council was not able to reach unanimous support and while the Council had initially paused negotiations to provide room for the OECD/G20 Inclusive Framework's reform of corporate tax rules, the 2016 CCCTB proposal was withdrawn in September 2023.

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6.11.2025 A10-0194/84

Amendment 84

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 2

Text proposed by the Commission

Amendment

(2) The existence of 27 different corporate income tax systems in the Union gives rise to complexity in tax compliance and leads to unfair competition for businesses. That has become more evident as globalisation and digitalisation of the economy have significantly altered the perception of land borders and business models. As governments have tried to adapt to that new reality, a fragmented response among Member States has led to further distortions in the internal market. The various legal frameworks inevitably lead to different tax administration practices across the Member States as well. This often entails long procedures characterised by unpredictability and inconsistency along with high compliance costs.

(2) The existence of 27 different corporate income tax systems in the Union gives rise to complexity in tax compliance and leads to unfair competition for businesses, especially because MNEs could use the different tax systems in order to engage in aggressive tax planning, resulting in SMEs having to pay a higher amount of taxes proportionally to their profits. That has become more evident as globalisation and digitalisation of the economy have significantly altered the perception of land borders and business models. As governments have tried to adapt to that new reality, a fragmented response among Member States has led to further distortions in the internal market. The various legal frameworks inevitably lead to different tax administration practices across the Member States as well. This often entails long procedures characterised by unpredictability and inconsistency along with high compliance costs. Most importantly, it leads to tax avoidance practices by MNEs.

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6.11.2025 A10-0194/85

Amendment 85

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 6

Text proposed by the Commission

Amendment

(6) It is indeed critical to create a system that achieves a degree of uniformity across the Union, at least amongst the taxpayers that it is chiefly addressed to. Accordingly, and considering the efforts that both tax administrations and businesses have made in order to implement the framework of a global minimum level of taxation, it would be important to capitalise on this achievement and design rules that remain as close as possible to the OECD/G20 Model Rules and Directive (EU) 2022/2523. On this basis, the common framework of rules should be mandatory for groups with a taxable presence in the Union provided that they have annual combined revenues of more than EUR 750 000 000 based on their consolidated financial statements. In this way, the scope would thus be targeted at businesses that are most likely to have cross-border activities and, thereby, can benefit from the simplification which a common legal framework would offer. The threshold would also provide alignment with Directive (EU) 2022/2523 for a consistent approach in the Union.

(6) It is indeed critical to create a system that achieves a degree of uniformity across the Union, at least amongst the taxpayers that it is chiefly addressed to. Accordingly, and considering the efforts that both tax administrations and businesses have made in order to implement the framework of a global minimum level of taxation, it would be important to capitalise on this achievement and design rules that remain as close as possible to the OECD/G20 Model Rules and Directive (EU) 2022/2523. On this basis, the common framework of rules should be mandatory for groups with a taxable presence in the Union provided that they have annual combined revenues of EUR 40 000 000 or more, in line with the criteria to be a large group within the meaning of Directive 2013/34/EU of the European Parliament and of the Council1a based on their consolidated financial statements. In this way, the scope would thus be targeted at businesses that are most likely to have cross-border activities and, thereby, can benefit from the simplification which a common legal framework would offer. The threshold would also provide alignment with Directive (EU) 2022/2523 for a consistent approach in the Union.

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1a Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the annual financial statements, consolidated financial statements and related reports of certain types of undertakings, amending Directive 2006/43/EC of the European Parliament and of the Council and repealing Council Directives 78/660/EEC and 83/349/EEC (OJ L 182, 29.6.2013, p. 19).

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6.11.2025 A10-0194/86

Amendment 86

Manon Aubry, Pasquale Tridico, Martin Schirdewan, Jussi Saramo

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 7 a (new)

Text proposed by the Commission

Amendment

(7 a) The Union should actively engage in international negotiations with a view to promoting the global harmonisation of rules and the allocation of taxing rights based on a formula reflecting tangible factors such as labour, assets and sales. The ongoing negotiations within the United Nations on international tax cooperation are a unique and timely opportunity in that regard. In that context, the abstention of several Member States is regrettable and they should be strongly encouraged to participate constructively and proactively in those discussions.

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6.11.2025 A10-0194/87

Amendment 87

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 7 b (new)

Text proposed by the Commission

Amendment

(7 b) In order to avoid the delocalisation of profits outside the Union by MNEs, BEFIT groups should also declare their global profit at the international level. The formula used in this Directive would then also be used to compare the profits originally declared in the Union with the ones that would have been declared if the formula was applied to the global profits of the BEFIT group. If the corrected profits are higher than the declared profits, the Union will tax those corrected profits thanks to the formula included in this Directive.

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6.11.2025 A10-0194/88

Amendment 88

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Recital 7 c (new)

Text proposed by the Commission

Amendment

(7 c) To fight against global tax avoidance, Member States could also unilaterally collect the tax deficit of multinationals: the difference between what a corporation pays in taxes globally and what it would have to pay if all of its profits were subject to a minimum tax rate in each of the countries in which it operates. Such a solution could encourage other countries to follow that move and progressively lead to an ambitious global solution.

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6.11.2025 A10-0194/89

Amendment 89

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Article 2 – paragraph 1 – point a

Text proposed by the Commission

Amendment

(a) they belong to a domestic group or to a multinational enterprise group (‘MNE group) which prepares consolidated financial statements and had annual combined revenues of EUR 750 000 000 or more in at least two of the last four fiscal years;

(a) they belong to a domestic group or to a multinational enterprise group (‘MNE group) which prepares consolidated financial statements and had annual combined revenues of EUR 40 000 000 or more in at least two of the last four fiscal years;

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6.11.2025 A10-0194/90

Amendment 90

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Article 15 – paragraph 1

Text proposed by the Commission

Amendment

The financial accounting net income or loss of a BEFIT group member carrying out shipping activities shall be adjusted to exclude the amount of revenues, expenses and other deductible items derived from such activities covered by a tonnage tax regime.

deleted

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6.11.2025 A10-0194/91

Amendment 91

Manon Aubry, Pasquale Tridico

on behalf of The Left Group

Report A10-0194/2025

Evelyn Regner

Business in Europe: Framework for Income Taxation (BEFIT)

(COM(2023)0532 – C9-0341/2023 – 2023/0321(CNS))

Proposal for a directive

Article 42 – paragraph 2 – point b

Text proposed by the Commission

Amendment

(b) a negative amount, the loss shall be carried forward and shall be set off against the next positive BEFIT tax base.

deleted

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