Council Directive (EU) 2022/2523 implements the agreement reached on 8 October 2021 by the OECD/G20 Inclusive Framework (OECD/G20 IF) on base erosion and profit shifting (BEPS) and closely follows the Global Anti-Base Erosion Model Rules (Pillar Two) of Organisation for Economic Co-operation and Development (OECD) (OECD Model Rules) agreed by the OECD/G20 IF on 14 December 2021. Directive (EU) 2022/2523 introduces a qualified income inclusion rule (IIR) and a qualified undertaxed profit rule (UTPR). That Directive also allows Member States to introduce their own qualified domestic top-up tax (QDTT).
Text as published in the Official Journal, reproduced verbatim (including any typographical quirks of the source). For the authentic version, see EUR-Lex.
