Európai Unió : hírek magyarul

Written by Pieter Baert.

G7 statement

On 28 June 2025, the G7 issued a statement expressing a ‘shared understanding’ that the domestic and foreign profits of US-parented multinational groups would be excluded from the scope of Pillar Two, the OECD-G20 global minimum corporate tax framework. Instead, the G7 signalled readiness to work on a ‘side-by-side’ approach in which the US GILTI regime, its current minimum tax on foreign earnings of US parented groups – would co-exist with Pillar Two. The statement allowed for the withdrawal of proposed US retaliatory measures (‘section 899’) that had been included in the One Big Beautiful Bill Act (OBBBA).

Reminder: Pillar Two applies a 15 % global minimum effective tax rate using a hierarchical rule order to ensure large multinational enterprises are taxed appropriately in each jurisdiction:

• 1. The Qualified Domestic Minimum Top-Up Tax (QDMTT) – Gives the local jurisdiction first claim to top up low-taxed domestic profits.
• 2. The Income Inclusion Rule (IIR) – The ultimate parent’s jurisdiction imposes a top-up tax on the local parent entity to make up for any remaining low-taxed profits of foreign entities.
• 3. The Undertaxed Profits Rule (UTPR) – If the IIR is not applied by the ultimate parent’s jurisdiction, the UTPR steps in as a backstop, with lower-tier jurisdictions imposing top-up taxes on local entities to make up for any remaining low-taxed profits in the parent jurisdiction or any other third jurisdiction.

Council Directive (EU) 2022/2523 introduced Pillar Two’s minimum tax rules in the EU.

Given the broad nature of the G7 statement, which speaks of ‘accepted principles’, it is difficult to draw definitive conclusions at this stage. Based on its wording, a side-by-side approach – if endorsed by the OECD Inclusive Framework – could imply that non-US jurisdictions would not apply the UTPR to local entities of US-parented groups in respect of low-taxed profits arising in the US or in another jurisdiction that does not apply the QDMTT or the IIR. However, the statement does not explicitly clarify the specific terms of the exemption. For instance, it does not address how US intermediary parent entities within non-US multinational groups would be treated for minimum tax purposes, the potential creditability of the GILTI tax in relation to a jurisdiction’s QDMTT, or how the side-by-side approach would be defined in legislation.

NCTI and Pillar Two

As Pillar Two and the US’ GILTI (now called ‘NCTI’ under the OBBBA) operate on different principles and design features, it is difficult to assess to what extent the side-by-side approach could raise concerns about a level playing field or lead to base erosion and profit shifting among the multinational companies subject to each regime. Potential competitive disadvantages arise not only from differences in direct tax liabilities but also from the variations in the administrative and legal complexity of the respective regimes.

The OBBBA, signed into law in July 2025, introduced several adjustments allowing NCTI to more accurately reflect the real outcomes of Pillar Two. It increased the effective tax rate to 14 % (up from 13.125 %) and removed the carve-out for the Qualified Business Asset Investment (QBAI), thereby broadening the taxable base.

However, a key difference between the two systems remains: the ‘blending’ of income. Pillar Two requires corporate groups to meet a minimum level of tax in each jurisdiction where they operate (‘jurisdictional blending’), while the US’ NCTI allows income and foreign taxes to be blended across all foreign countries (‘global blending’). This way, low-taxed income can be offset with high-taxed income elsewhere and profits in some jurisdictions can be reduced by losses in others.

Table 1 – Key comparisons between OECD G20 Pillar Two and US NCTI

 OECD-G20 – Pillar TwoUS – NCTITax rate15 %14 %Tax baseBased on accounting incomeBased on US taxable incomeBlendingJurisdictional blendingGlobal blendingCarve-outsBased on payroll and tangible assets (SBIE)Payroll or tangible assets do not qualify for a carve-out

Note: The effective 14 % floor of NCTI results from the interaction of the 21 % US statutory corporate tax rate, the 60% inclusion of NCTI taxable income and the 90 % foreign tax credit limitation ((21 % * 60 %)/90 % = 14 %).

Additionally, the OBBA introduced broader corporate tax changes, such as permanent expensing for domestic R&D investments and a higher interest deductibility cap, to enhance US competitiveness.

Pillar One

The G7’s statement noted that the delivery of the side-by-side system ‘will facilitate further progress to stabilize the international tax system, including a constructive dialogue on the taxation of the digital economy’, referencing the negotiations on Pillar One. During the September 2025 plenary session, in response to questions from Members of the European Parliament on Pillar One and the prospects for a European digital services tax (DST), the European Commission acknowledged that Pillar One discussions were ‘on hold’ but could resume once a Pillar Two solution is reached. To give the OECD-led process space and time to deliver, the Commission stated that it does not intend to table a new proposal for a DST at this stage.

Several countries have already implemented or announced digital services taxes (DSTs), with revenues steadily increasing over time, showcasing the continuous growth of the digital economy. In 2023, Spain, Italy and France collectively generated €1.4 billion from their DSTs. However, estimating the revenue potential of an EU-wide DST would heavily depend on key design parameters, such as the definition of in-scope activities (the types of digital services or business activities that would fall under the tax), the applicable tax rate, and the revenue thresholds.

Table 2 – Revenue of DSTs, € million, 2019-2023

Revenue (€ million)20192020202120222023Spain  €166€295€323France€277€375€474€621€668Italy €233€303€394€434

Data source: Data on Taxation Trends – European Commission. All three countries apply a 3 % DST on turnover from online advertising, user data sales and digital platforms, with a €750 million global revenue threshold and varying domestic thresholds: €3 million (Spain), €25 million (France), and €5.5 million (Italy; lowered to €0 in 2025).

Read this ‘at a glance’ note on ‘Side by side? The future of Pillar Two minimum corporate tax rules‘ in the Think Tank pages of the European Parliament.

It is no secret that CPEC has failed to achieve its set goals on time. But is China to blame – or Pakistan itself?

In his annual State of the Nation speech, Tokayev gave new insights into how he envisions the development of Kazakhstan as a digital state.

Kazakhstan should be, and has been, commended for strengthening legal protections for women and holding perpetrators accountable, but more must be done.

The Assam government’s decisions on land transfers are likely to reignite tensions in a state with a history of violence against alleged outsiders.

An ambitious policy framework has translated into limited change in Kazakhstan. Why?     

A few sunlit ridges beside ice-rich craters could become lunar chokepoints, unless Asia writes simple, shared rules now.

India’s navy is the only one that operates persistently between Qatar, the forward HQ of the US CENTCOM, and the Malacca Strait, which leads into the South China Sea.

While ACD removes structural barriers to cooperation, at the same time it is supposed to gradually reduce Japan’s overreliance on U.S. cyberdefense systems. 

Even though China’s role in South Asia has grown in the last decade, Beijing has little by way of policy or strategy when it comes to dealing with political instability in the region. 

This is Pakistan’s most significant formal defense pact in decades, and the first such agreement that an Arab Gulf state has inked with a nuclear-armed partner.

Leaked documents from Geedge Networks and GoLaxy show how repression in China is both a political imperative and a profitable business.

That Indonesia’s costly high-speed rail is operating at a loss right out of the gate has raised some eyebrows.

Kim Jong Un showed his tit-for-tat move against the latest South Korea-U.S. military drills.

China’s limited success in managing the political risks of the BRI has resulted in reputational costs and played a role in China’s curtailed flow of BRI lending in recent years.

Far from consolidating, recognition by the international community could expose the group’s rifts over resources, external demands, and identity.

Written by Gisela Grieger.

The importance of the EU’s trade defence arsenal is underscored, among other factors, by persistent global overcapacity in a range of sectors, which has significant distorting effects on international markets, and by the weaponisation of trade, including through economic coercion amid growing geopolitical tensions.

The arsenal can be divided into two categories. First, the EU’s traditional trade defensive instruments (TDIs), which are based on multilateral trade agreements going back to Codes developed under the 1947 General Agreement on Tariffs and Trade; and second, the EU’s more recent autonomous trade instruments, most of which were enacted between 2019 and 2024.

TDIs enable the EU to deter and combat unfair trade practices from companies and public authorities of third countries, shield EU industries and jobs from these practices, and restore a level playing field for EU companies in the internal market. TDIs are mainly applied in the form of additional duties on imports of dumped and/or subsidised goods, or on goods whose imports have surged suddenly and unexpectedly and have caused serious injury to EU industry – or threaten to do so.

The EU’s autonomous trade instruments seek to fill regulatory gaps in international trade law in areas such as public procurement and foreign subsidies, with a view to levelling the playing field between EU companies and non-EU companies and to safeguarding the EU’s economic interests, including its economic security.

Against the backdrop of the United States’ recent unilateral tariff policies, which are likely to lead to a diversion of trade flows to other markets, including the EU, and to a further increase in the global use of trade defence measures, the relevance of the EU’s trade defence toolbox is set to grow in the future.

Read the complete briefing on ‘Understanding the EU trade defence toolbox‘ in the Think Tank pages of the European Parliament.

Council amends existing regulations to address current and emerging challenges in the context of the mid-term review of EU cohesion policy.

In light of Russia’s ongoing war of aggression against Ukraine and following the repeated violation of the airspace of our Member States by Russian drones, ZAPAD-2025 does not demonstrate a commitment to de-escalation and peace. The participation of other countries, especially from Belarus, in this context raises serious security concerns. The EU calls for full compliance with international agreements and remains vigilant regarding potential security threats.

Déclaration à la presse du président António Costa à l'issue de sa rencontre avec le Premier ministre luxembourgeois, Luc Frieden.