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Changes from report parliamentary committee draft to plenary report

ECON-PR-773162 → A-10-2025-0194

From
ECON-PR-773162 report parliamentary committee draft of 12 May 2025
To
A-10-2025-0194 Plenary report of 16 Oct 2025
Changes
28 changes to the text
Paragraphs
+68 added · −59 removed · 14 changed
More facts (3)
Title (from)
on the proposal for a Council directive on Business in Europe: Framework for Income Taxation (BEFIT)
Title (to)
on the proposal for a Council directive on Business in Europe: Framework for Income Taxation (BEFIT)
AI: What changed, in short Written by AI from the official text — check the source · deepseek-v4-flash · 4 Sept 2026

Introduces significant economic presence as a taxable nexus with a EUR 1 million revenue threshold, extending permanent establishment rules.7810 Adds new anti-abuse rules: royalties limitation, controlled foreign company rules, and stricter interest limitation.1011 Replaces the transitional allocation with a permanent formula based on sales, labour, assets, and digital presence, and adds accelerated depreciation.122027 Removes the optional scope for smaller groups and the individual tax return system, simplifying procedures.52223 Other changes are formal or wording: updated references, changed numbers, and rephrased recitals.1346

The notes class 21 changes as substance, 5 as formal, 2 as wording only.

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Part 5 of 5: BUDGETARY ASSESSMENT OF THE COMMITTEE ON BUDGETS

Change 28

AddedBUDGETARY ASSESSMENT OF THE COMMITTEE ON BUDGETS

Addedfor the Committee on Economic and Monetary Affairs

Addedon the proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT)

Added(COM(2023)0532– C9-0341/2023 – 2023/0321(CNS))

AddedRapporteur for budgetary assessment: Danuše Nerudová

AddedThe Committee on Budgets has carried out a budgetary assessment of the proposal under Rule 58 of the Rules of Procedure and has reached the following conclusions:

AddedThe Committee on Budgets,

Added1. Recalls that businesses benefit from the Union single market, harmonised policies and regulatory framework, which enhance their international competitiveness; considers it fair that a share of their profits contributes to, or is deemed to contribute to, the Union budget accordingly; highlights that the ‘Business in Europe: Framework for Income Taxation’ (BEFIT) framework could reduce revenue leakage, as it would provide the EU with more transparent rules on corporate taxation;

Added2. Recalls that over the years Parliament has repeatedly supported Commission initiatives for tax-based own resources such as the Common Consolidated Corporate Tax Base (CCCTB), the Digital Services Tax or the OECD Pillar One approach; regrets that none of these initiatives has so far achieved the necessary support in the Council to bring them into force; calls on the Commission and the Member States to urgently step up the work towards an agreement on those initiatives;

Added3. Underlines that the roadmap for the introduction of new own resources spelled out in the legally binding Interinstitutional Agreement explicitly mentions a new own resource linked to corporate taxation as part of a basket of new revenue sources; notes that without the introduction of the BEFIT framework it will be difficult to define and adopt any practicable tax base for a new own resource;

Added4. Determines that the proposal for the BEFIT framework is fully compatible with a genuine corporate tax-based own resource as well as with a statistics-based national contribution as proposed by the Commission in the amended proposal for Own Resources Decision (COM(2023)0331) and as endorsed by Parliament in its legislative resolution of 9 November 2023;

Added5. Highlights, moreover, that the BEFIT initiative, by establishing a harmonised framework for income taxation, constitutes a viable starting point for the introduction of a new own resource as foreseen in the IIA roadmap; affirms that the introduction of a new own resource consisting of a national contribution based on BEFIT could provide one of the most stable revenue streams for the EU budget, which is under significant strain, particularly due to debt repayment commitments and the increasing spending needs in the context of the multiple challenges the EU is currently facing, including the new geopolitical context; considers that all new Union policies and challenges must involve new financial means and additional fresh resources; underlines that the development of a harmonised framework for corporate income taxation reinforces the sustainability and predictability of the Union budget, while ensuring the viability of the repayment of the debt incurred under NextGenerationEU (NGEU); observes, furthermore, that the modifications of the tax base allocation have been modelled on the OECD Pillar One approach, which has also been proposed as a starting point for the calculation of a corporate tax-based own resource; calls, therefore, on the Member States to swiftly adopt this directive and on the Commission to update the existing proposal for new own resources accordingly;

Added6. Regrets, nevertheless, that the timeline envisaged for the establishment of BEFIT, including time for Council negotiations, entry into application, transitional period and review would stretch far into the 2030s and would thus be difficult to reconcile with the roadmap and the temporal profile of the NGEU repayment needs; recalls that according to the legally binding IIA roadmap, such an own resource should enter into force by 1 January 2026;

Added7. Recalls, in this context, that Parliament has recently endorsed the Commission proposal for an own resource conceived as a national contribution based on statistics about the gross operational surplus of companies in the financial and non-financial sectors (CPOR); holds that such an own resource, coherently conceived, would go hand in hand with the establishment of a more harmonised calculation base which would be considered by Member States as an equitable foundation of an EU revenue source; underscores that a statistics-based national contribution would not depend on any underlying tax directive and could draw directly on the annual aggregate Eurostat figures of gross profits, which would constitute a proxy for a harmonised tax base; considers that such a transitional arrangement might even serve to incentivise Member States to accelerate negotiations and reach a swifter agreement on BEFIT;

Added8. Underlines that neither an own resource based on BEFIT nor a statistics-based national contribution should result in any additional burden for companies or lead indirectly to additional taxation of citizens; recalls in this regard that the main objective of the BEFIT proposal is to simplify tax rules, ensure more tax harmonisation in the EU, increase tax certainty and foster a level playing field for EU businesses while strengthening the Single market, cross-border trade and the competitiveness of European companies;

Added9. Regrets the absence of tangible progress in the Council on the introduction of new own resources; reiterates its call on the Council to adopt without further delay the new own resources meant to cover the repayment of NGEU borrowing costs and to sufficiently fund the Union’s policies and priorities; calls on the Commission to go beyond the current proposal on new own resources and to adapt the existing basket to reflect changes in the geopolitical situation, as well as to seek far-reaching political compromises on new own resources proposals; urges the Commission to reflect in its future proposal the principles set out in the roadmap for the introduction of new own resources enshrined in the IIA whereby new own resources should be aligned with Union priorities; is concerned that, without new sources of revenue, up to almost 20 % of the annual EU budget might be sacrificed to cover the repayment costs of NGEU; highlights, in this regard, the commitment under the IIA that the expenditure from the Union budget related to NGEU repayments should not lead to an undue reduction in programme expenditure or investment instruments under the MFF.

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Where the facts on this page come from, and how to cite it.

Data source
Licensed CC BY 4.0.
Retrieved
27 September 2026

Cite as

European Parliament (2025). “Changes between ECON-PR-773162 and A-10-2025-0194”. Text, 16 October 2025. from ECON-PR-773162, to A-10-2025-0194, reference 2023/0321(CNS). EU Parl Watch Research. https://news.eu-parl.st-solutions.dev/texts/ECON-PR-773162/compare/A-10-2025-0194?all=1&part=5 (retrieved 27 September 2026). Data: European Parliament Open Data, https://data.europarl.europa.eu/ (CC BY 4.0).
BibTeX
@misc{epw-text-2025-10-16,
  author = {{European Parliament}},
  title = {{Changes between ECON-PR-773162 and A-10-2025-0194}},
  year = {2025},
  date = {2025-10-16},
  howpublished = {\url{https://news.eu-parl.st-solutions.dev/texts/ECON-PR-773162/compare/A-10-2025-0194?all=1&part=5}},
  url = {https://news.eu-parl.st-solutions.dev/texts/ECON-PR-773162/compare/A-10-2025-0194?all=1&part=5},
  urldate = {2026-09-27},
  publisher = {EU Parl Watch Research},
  note = {Text. from ECON-PR-773162, to A-10-2025-0194, reference 2023/0321(CNS). Data: European Parliament Open Data (CC BY 4.0)}
}