What changed between the plenary report and the adopted text

The European Parliament,

– having regard to the Treaty on the Functioning of the European Union, in particular Article 4 and Articles 63 to 66 thereof on the principles of the internal market, free movement of goods, services, capital and people, and of Articles 113, 114 and 115 thereof,

– having regard to Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States (the Interest and Royalties Directive),

– having regard to Council Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive),

– having regard to Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation [15 %] for multinational enterprise groups and large-scale domestic groups in the Union, which is the EU’s response to international tax coordination,

– having regard to the ongoing developments concerning the EU’s two-pillar solution to address the tax challenges arising from the digitalisation of the economy,

– having regard to the final reports of October 2015 published by the Organisation for Economic Co-operation and Development (OECD) on the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project,

– having regard to the reports on the Pillar One and Pillar Two Blueprints adopted by the OECD/G20 Inclusive Framework on 14 October 2020, and to the results of the OECD economic analysis and impact assessment of 12 October 2020 entitled ‘Tax Challenges Arising from Digitalisation – Economic Impact Assessment’,

– having regard to the OECD/G20 Inclusive Framework on BEPS statement of 8 October 2021 on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy,

– having regard to the Pillar Two model rules of the OECD/G20 Inclusive Framework on BEPS of 20 December 2021 for domestic implementation of 15 % global minimum tax,

– having regard to United States Public Law 117-169 of 16 August 2022, known as the Inflation Reduction Act,

– having regard to the G20 Rio de Janeiro Leaders’ Declaration of 19 November 2024 and the G20 Rio de Janeiro Ministerial Declaration on International Tax Cooperation of 25 July 2024,

– having regard to UN General Assembly Resolution 79/235 of 24 December 2024, on the promotion of inclusive and effective international tax cooperation at the UN,

– having regard to the Commission communication of 15 July 2020 entitled ‘An action plan for fair and simple taxation supporting the recovery strategy’ (COM(2020)0312),

– having regard to the Commission communication of 18 May 2021 entitled ‘Business Taxation for the 21st Century’ (COM(2021)0251),

– having regard to the Commission proposal of 22 December 2021 for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union (COM(2021)0823), as well as to Parliament’s position of 19 May 2022 on this proposal,

– having regard to the Commission study of January 2022 entitled ‘Tax compliance costs for SMEs: An update and a complement – final report’,

– having regard to the Commission proposal of 11 May 2022 for a Council Directive on laying down rules on a debt-equity bias reduction allowance and on limiting the deductibility of interest for corporate income tax purposes (COM(2022)0216),

– having regard to the Commission proposal of 8 December 2022 amending Directive 2006/112/EC as regards VAT rules for the digital age (COM(2022)0701),

– having regard to the Commission proposal of 8 December 2022 for a Council Regulation amending Regulation (EU) No 904/2010 as regards the VAT administrative cooperation arrangements needed for the digital age (COM(2022)0703),

– having regard to the Commission proposal of 8 July 2024 for a Council Directive amending Directive 2006/112/EC as regards the electronic value added tax exemption certificate (COM(2024)0278),

– having regard to the Council agreement on VAT in the digital age package of 5 November 2024,

– having regard to Council Directive (EU) 2025/50 of 10 December 2024 on faster and safer relief of excess withholding taxes (FASTER),

– having regard to the Commission proposal of 12 September 2023 for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT) (COM(2023)0532),

– having regard to the Commission proposal of 12 September 2023 for a Council Directive establishing a Head Office Tax system for micro, small and medium sized enterprises, and amending Directive 2011/16/EU (COM(2023)0528),

– having regard to the Commission proposal of 12 September 2023 for a Council Directive on transfer pricing (COM(2023)0529),

– having regard to the European Council conclusions of 17 and 18 April 2024 on a new European competitiveness deal,

– having regard to the Council conclusions of 24 May 2024 on a Single Market for the benefit of all,

– having regard to the European Council’s Budapest declaration on the New European Competitiveness Deal, adopted on 8 November 2024,

– having regard to the Council conclusions of 11 March 2025 on a tax decluttering and simplification agenda which contributes to the EU’s competitiveness,

– having regard to the European Council conclusions of 20 March 2025 on competitiveness, with a focus on simplification and the reduction of regulatory and administrative burdens,

– having regard to its resolution of 16 February 2022 on the implementation of the Sixth VAT Directive: what is the missing part to reduce the EU VAT gap?,

– having regard to its resolution of 7 October 2021 on reforming the EU policy on harmful tax practices (including the reform of the Code of Conduct Group),

– having regard to its resolution of 15 February 2022 on the impact of national tax reforms on the EU economy,

– having regard to its resolution of 10 March 2022 on a European Withholding Tax framework, calling for a standardised withholding tax framework,

– having regard to its resolution of 4 October 2022 on the impact of new technologies on taxation: crypto and blockchain,

– having regard to its resolution of 10 March 2022 with recommendations to the Commission on fair and simple taxation supporting the recovery strategy (EP follow-up to the July Commission’s Action Plan and its 25 initiatives in the area of VAT, business and individual taxation),

– having regard to its resolution of 4 May 2022 on the follow-up to the conclusions of the Conference on the Future of Europe,

– having regard to the Commission Joint Research Centre’s study of 19 April 2022 entitled ‘Local taxes on economic activity in municipalities in EU Member States’,

– having regard to its resolution of 15 June 2023 on lessons learnt from the Pandora Papers and other revelations, also calling for the improvement of reporting and information sharing,

– having regard to its resolution of 12 December 2023 on further reform of corporate taxation rules,

– having regard to the report of 9 May 2022 on the final outcome of the Conference on the Future of Europe,

– having regard to the report by Enrico Letta of April 2024 entitled ‘Much more than a market’,

– having regard to the report by Mario Draghi of 9 September 2024 entitled ‘The future of European competitiveness’,

– having regard to Rule 55 of its Rules of Procedure,

– having regard to the report of the Committee on Economic and Monetary Affairs (A10-0155/2025),

A. whereas effective, fair and efficient tax policies play a key role in promoting long-term sustainable growth and inclusive societies;