The European Association of Cooperative Banks (EACB) gladly takes the opportunity to comment on the new OECD consultation about for the Blueprints of Pillar 1 and 2. We recognise the good work done so far and encourage you to continue to prepare proposals for the new rules, as we believe it is better for countries to agree on a uniform system rather than individual "island solutions" which will have to be implemented by companies on a country-specific basis. The EACB welcomes the OECD's proposals on Pillar 1 and 2.
Concerning Pillar 1, the EACB recognises the difficulty to build compromises. Regarding complexity, it should always be borne in mind that even institutions that are not "in scope" with regard to "Amount A" must make extensive administrative efforts to determine this amount. We therefore suggest that, where possible, more use should be made of formulaic calculation methods. EACB members are satisfied that financial Services are exempted from the scope of Pillar 1.
Concerning Pillar 2, the EACB believes that the financial sector should be exempted by the new minimum taxation under Pillar 2. This carve-out should be granted to financial sector both for simplification and, in particular, for compliance cost reasons. Finally, concerning Pillar 2 in general, the aspect of "tax certainty" should be elaborated even further, as companies need legal certainty.