Legislative Train Schedule
European Parliament
Please fill in this field to search

Business in Europe: Framework for Income Taxation (BEFIT)

In “A new plan for Europe's sustainable prosperity and competitiveness”

Information updated as of 20/06/2026.
Go back to previous editions:

Following the global agreement on international corporate taxation reform at the OECD/ Inclusive Framework in October 2021, the European Commission signaled that "a closely integrated European Union and Single Market can and should go further". In this context, the European Commission announced they would launch a proposal called 'BEFIT' (Business in Europe: Framework for Income Taxation) in 2023. This BEFIT proposal would replace the proposals for a Common Corporate Tax Base (CCTB) and a Common Consolidated Corporate Tax Base (CCCTB), which would be withdrawn.     

In September 2023, the European Commission tabled the BEFIT proposal. As a main motivation, the Commission argued that the different national tax rules in each EU country make it difficult for (large) European businesses to comply with all their tax obligations. This discourages cross-border investment in the EU and puts European businesses at a competitive disadvantage compared to companies elsewhere in the world. Building on the OECD/Inclusive Framework agreement on Pillar Two, the European Commission puts forward a method to calculate an aggregated tax base for the companies and permanent establishments of a BEFIT group, and to allocate the tax base between the different members of the BEFIT group.

The new rules will be mandatory for groups operating in the EU with an annual combined revenue of at least €750 million, and where the ultimate parent entity holds at least 75% of the ownership rights or of the rights giving entitlement to profit. Smaller companies would be able to opt in, if they so wish.

The proposal requires unanimity in the Council for its adoption, following consultation of the European Parliament and the European Economic and Social Committee (special legislative procedure).

In the European Parliament, the proposal was assigned to the Economic and Monetary Affairs Committee (Rapporteur: Evelyn Regner, S&D, Austria). The European Parliament adopted its (non-binding) opinion in plenary in November 2025.

In Council, the technical examination of the proposal is ongoing in the Working Party on Tax Questions (Direct taxation). During the Belgian presidency of the Council in the first half of 2024, detailed discussions were held on numerous provisions of the BEFIT proposal, primarily about potentially further aligning them with Pillar Two rules. Several Member States expressed their concern on whether the proposal would successfully achieve lower compliance costs for companies and tax authorities and simplification of the corporate tax system. During the Hungarian presidency of the Council in the second half of 2024, technical discussions continued on various topics (including depreciation, timing and the allocation of the BEFIT tax base). The Council considered that further reflection and technical work would be necessary to determine the next steps in the negotiations.

References:

Further reading:

Members' Research Service, legislative-train@europarl.europa.eu