EU Council Adopts New Directives At ECOFIN Meeting

On December 6, during the ECOFIN meeting the Council of the EU adopted directive granting access for tax authorities to beneficial ownership information. The Council also achieved consensus on a 'hybrid mismatches' draft directive with regards to third countries. It also endorsed common corporate tax base proposal (CCTB) and various Transfer Pricing directives from OECD BEPS Reports.

Beneficial Ownership

The new rules ensuring that tax authorities in the EU will access data collected under current anti-money laundering rules. This includes important information such as customer due diligence records and information held in national beneficial ownership registries. Tax authorities will now be able to easily identify the ultimate owner behind an opaque company or entity.

The directive will apply as from 1 January 2018 and member states will have until 31 December 2017 to transpose the directive into national laws and regulations.


The Council endorsed a two-step approach for a common corporate tax base proposal (CCTB) and the consolidation of taxable corporate income (CCCTB). It supported the view that tax consolidation should be considered without delay.

Hybrid Mismatch

The Council achieved broad consensus on a draft directive aimed at closing down 'hybrid mismatches' with the tax systems of third countries. In order to finalize the directive, the Council will only need to resolve the rules that would allow member states to apply limited exemptions and the date of implementation.

OECD TP Guidelines

The Council endorses the OECD BEPS report on Aligning Transfer Pricing Outcomes with Value Creation (Actions 8-9-10). It also endorsed the OECD BEPS report on Aligning Transfer Pricing Outcomes with Value Creation (Actions 8-9-10) and transactional profit split method among other related subject.

Sources: Beneficial Ownership - EC Press Release, Main Results - ECOFIN Meeting Press Release, Outcomes of the Meeting (PDF)

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