EACB welcomes the opportunity to comment on the European Commission’s initiative on BEFIT.
Regarding the policy options, the EACB would like to state that should BEFIT consist in adding a rule to the existing local rules, the complexity of the tax rules will increase (i.e., there will be even more rules to be implemented and follow), as well as the compliance costs that will be added to the costs of implementing Pillar 2. In this context, the implementation of BEFIT might not be appropriate to us.
However, should the current legislation be improved by means of a directive (Option 2 in the current Call for Evidence), it should be based on existing regimes such as Pillar 2 and/or the country-by-country reporting (CBCR) and be as simple as possible.