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Compliance and Reporting Shifts in the EU Tax Simplification Package for Multinationals

The EU’s new tax simplification proposals abolish withholding taxes within the single market and streamline cross-border reporting—crucial compliance changes for global groups operating in the EU.

By NomadicTax Research Team · 5-8 min read

What the EU Proposes in Its Tax Simplification Package

On 24 June 2026, the European Commission unveiled a sweeping Tax Simplification Package comprising two major legislative proposals: the Direct Taxation Omnibus Directive and a Recast Directive on Administrative Cooperation (DAC). These aim to simplify EU direct tax rules, reduce compliance burdens, and enhance competitiveness across the Single Market. (taxation-customs.ec.europa.eu) Key measures include:

  • Abolition of withholding taxes on cross-border payments (dividends, interest, royalties) between EU companies. (taxation-customs.ec.europa.eu)
  • Expanding the Tax Merger Directive to include all corporate reorganisations under EU company law (mergers, divisions, asset transfers) to be tax-neutral. (taxation-customs.ec.europa.eu)
  • Recasting DAC directives into a single instrument for clearer, simpler reporting and removing duplicate or low-value obligations. (taxation-customs.ec.europa.eu)
  • Increase thresholds and remove reporting duties for millions of private sellers and for certain low-risk cross-border arrangements. (ec.europa.eu)

Implications for Multinational Groups and Businesses

  • Lowered barriers to remit profits, interest, royalties: Without withholding tax, EU subsidiaries transfer internal payments more efficiently.
  • Cross-border restructurings made easier: Tax-neutral reorganisations reduce tax friction when reorganising group structures across member states.
  • Reduced reporting burden: The DAC recast will cut unnecessary red tape; fewer notifications, fewer low-risk filings; huge relief especially for SMEs and e-commerce sellers.
  • Greater legal certainty: Codification of multiple directives provides clearer rules and reduces ambiguity.

How to Prepare

  • Review internal payment flows to determine future withholding positions on dividends, interest, royalties among group companies.
  • Audit potential reorganisations: Check whether proposed changes to company law could allow or affect upcoming strategic restructurings.
  • Track thresholds and notification requirements especially in online commerce and DAC reporting. If selling goods across borders or receiving royalties, know whether you’re subject to new rules.
  • Stay updated through national transpositions: the directives require EU member states to enact domestic laws to align with the new package—it may vary across countries.

Example Scenario

An EU-based tech group has entities in Germany and Spain. Under current rules, Spain withholds 15% on royalties paid to its German sister. Under the new omnibus rules, withstood withholding should be abolished. Also, if the group wants to split a business line into a new entity via a division (recognized under company law), they may do so without triggering immediate tax recognition.

Key Insights and Actionable Points

  • These proposals are medium-to-high impact for any non-U.S. multinational with structures in the EU—particularly those doing cross-border payments, holding IP, or engaged in group reorganisations.
  • Timing is critical: once the directives are adopted and then transposed, businesses should act to maximise benefits under old rules if needed.
  • Tax-efficient design should now assume no withholding within the EU as base case.
  • The removal of low-value and duplicative reporting will particularly help SMEs and digital platforms.

Author: NomadicTax Research Team

Sources

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