Pillar Two and BEFIT: Shocks and Opportunities for the EU Internal Market

The OECD BEPS Project has had a profound influence on EU tax policy. It is increasingly shaping the internal market and national corporate tax law. Following implementation of the Anti-Tax Avoidance Directive (2016/1164) and the Minimum Taxation Directive (2022/2523) (both stemming from the OECD’s Pillar Two set of rules), the European Commission recently brought forward, inter alia, the Proposal for a BEFIT Directive. Against the background of the harmonization competences granted to the Union in the Treaty on the Functioning of the European Union (2007), this article highlights Pillar Two, as well as the BEFIT proposal, and provides an outlook on tax accounting in general.