BEFIT is a common corporate tax framework for large groups within the EU. Our comments to the BEFIT Proposal have been divided into four parts and focus on some critical issues that we identified:

  1. Firstly, we focus on some general issues that may hamper achieving the objectives.
  2. Secondly, we address more technical issues regarding specific provisions in relation to scope and administrative procedure.
  3. Thirdly, we discuss the transfer pricing clauses.
  4. Finally, we elaborate on the negative impact that the interaction with the Pillar Two rules might have. Various recommendations have been proposed as well.

The document submitted to the European Commission was prepared by Nicolas Lippens, Marieke Bakker, Linda Brosens, Rogier Sterk, Carlijne Brinkers and Lisanne Bergwerff.

Reading our feedback will give you more feeling for the direction the EU is heading towards and the various issues that in our view still need to be addressed. Should you wish to get more background information on this topic, please contact one of our BEFIT specialists.

To read the document in full, please click on the download button provided below.

Download

Loyens & Loeff submits feedback on BEFIT Proposal