On September 9, 2022 the Dutch Minister of Finance informed the Dutch House of Representatives that the Netherlands, France, Germany, Spain and Italy issued a Joined Statement on Pillar 2.
In a letter to the Dutch House of Representatives the Dutch Minister of Finance states amongst others that after the Commission debate of the Eurogroup/Ecofin Council meeting of September 8, 2022, the Netherlands was approached with the request whether the Netherlands was willing to issue a statement together with France, Germany, Italy and Spain regarding the negotiations for the directive and implementation of a global effective minimum level of taxation (Pillar 2). The statement emphasizes the desire for an agreement in the Council and underlines the commitment to implement Pillar 2 in 2023.
In line with various motions, the government has made maximum effort to ensure that the negotiations on (Pillar 1 and) Pillar 2 proceed successfully. The challenges facing the international tax system can be tackled most effectively in an as broad as possible context. The Netherlands support the energetic implementation as was last year agreed with 137 jurisdictions in the Inclusive Framework. The Minister states that she is pleased with the progress that has been made on both Pillars, but emphasizes that it is important to maintain momentum on this file. The Dutch Government therefore wants to send out a strong signal with this statement.
The text of the Joint Statement as issued by France, Germany, Spain, Italy and the Netherlands reads as follows:
“Implementation of the global minimum effective taxation in 2023
As inflation hits heavily the spending power of our fellow citizens, companies must pay their fair share of the burden to alleviate the impact of the global energy crisis.
This is why we reaffirm today our strengthened commitment to swiftly implement the global minimum effective corporate taxation. It is a key lever for further tax justice through a more efficient fight against tax optimization and evasion.
At the June 2022 Ecofin, 26 out of 27 EU member states expressed their willingness to implement this important step towards tax justice, and our first goal remains to gather a consensus. Should unanimity not be reached in the next weeks, our governments are fully determined to follow through on our commitment. We stand ready to implement the global minimum effective taxation in 2023 and by any possible legal means. We are also fully committed to complete the work on the better reallocation of taxing rights from huge global multinationals’ profits with the objective of signing a multilateral convention by mid-2023.”
Remarks AJT
Unfortunately the letter that the Dutch Minister sent to the Dutch House of Representatives does not provide any insight in whether any other EU Member States were asked to participate in the issuance of the joint statement. It is therefore unclear why the Joint Statement was only issued on behalf of 5 Member States and why the other 22 (or 21 if not taking Hungary into account were not mentioned).
Furthermore if you have followed my previous remarks regarding the 2 Pillar solution, you might have noticed that I am convinced that where the Two-Pillar might be beneficial to the larger jurisdictions as France, Germany, Spain and Italy it will be very damaging to the economies of smaller jurisdiction as for example those of the Netherlands, Belgium, Luxembourg, Austria and Ireland. So for me it is unclear why the Dutch Government has always been so overenthusiastic about the Two-Pillar solution and therefore also why she decided to participate in the issuance of the Joined Statement as the the only small jurisdiction of the five issuers.
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