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The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU tax law. We have summarized the highlights of this edition below.
EU Commission reaffirms commitment to OECD-Led discussion on digital taxation and rules out proposing an EU Digital Tax at this stage
On 10 September 2025, a representative from the European Commission confirmed that the discussions on Pillar 1 may resume later this year and that it is premature to consider alternatives to the OECD-led process. Furthermore, he noted that the Commission does not intend to propose an EU digital tax at this stage.
France's Constitutional Court upholds French Digital Service Tax (DST)
On 12 September 2025, the French Constitutional Council issued a landmark decision confirming the compatibility of France's Digital Service Tax (DST) with the French Constitution (Decision n° 2025-1157 QPC – September 12, 2025 Société Digital Classifieds France).
Belgian Constitutional Court refers case to the CJ on the compatibility of the UTPR with EU Law
On 17 July 2025, the Belgian Constitutional Court referred questions to the Court of Justice of the European Union (CJ) regarding the compatibility of the Undertaxed Profits Rule (UTPR), as implemented under the EU Minimum Tax Directive (2022/2523), with fundamental principles of EU law.
EU Commission Budget Proposal and Corporate Contribution (CORE) as New Own Resource: Discussions in the Council show pushback from Member States
On 16 July 2025, the European Commission presented its proposal for the next Multiannual Financial Framework (MFF), outlining a nearly EUR 2 trillion budget to guide EU investments between 2028 and 2034. To fund these priorities, while also repaying what the EU has borrowed under NextGenerationEU and reducing pressure on national budgets, the Commission presented new own resources, including a Corporate Resource for Europe (CORE).
CJ Judgment regarding VAT treatment of transfer pricing adjustments for intra-group services (Arcomet, C-726/23)
On 4 September 2025, the CJ delivered its judgment in the SC Arcomet Towercranes SRL (C‑726/23), where it ruled that transfer pricing adjustments may be subject to VAT when they are contractually stipulated in an intra-group agreement.
Regulation simplifying CBAM adopted by the Council of the European Union
On 29 September 2025, the Council of the European Union adopted a regulation introducing changes to the Carbon Border Adjustment Mechanism (CBAM) as part of the EU Omnibus simplification package, which also includes proposals for legislative changes to other EU sustainability legislation such as the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
US-EU trade developments: Joint Statement and Proposal
On 21 August 2025, the US and EU issued a Joint Statement outlining the framework of the political agreement that was reached on reached on 27 July 2025. In this EUTA we provide a concise overview of the commitments outlined in the Joint Statement.
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