Annexes to COM(2024)497 - Amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation

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agreement or grant decision or a contract funded under this Regulation.

3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE

3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s) affected

- Existing budget lines

In order of multiannual financial framework headings and budget lines.

Heading of multiannual financial frameworkBudget lineType of
expenditure
Contribution
Number 03 04 0100

Diff./Non-diff.17from EFTA countries18from candidate countries and potential candidates19fromother third countriesother assigned revenue
1 – Single Market, Innovation and DigitalImproving the proper functioning of the taxation systems

Diff.NONONONO

- New budget lines requested

In order of multiannual financial framework headings and budget lines.

Heading of multiannual financial frameworkBudget lineType of
expenditure
Contribution
Number

Diff./Non-diff.from EFTA countriesfrom candidate countries and potential candidatesfrom other third countriesother assigned revenue
[XX.YY.YY.YY]

YES/NOYES/NOYES/NOYES/NO

3.2. Estimated financial impact of the proposal on appropriations

3.2.1. Summary of estimated impact on operational appropriations

-  The proposal/initiative does not require the use of operational appropriations

- ☒ The proposal/initiative requires the use of operational appropriations, as explained below:

EUR million (to three decimal places)

Heading of multiannual financial
framework
NumberSingle Market, Innovation and Digital

DG: TAXUDYear
202420
Year
2025
Year
2026
Year
2027
Total
□ Operational appropriations
Budget line21 03.04.01Commitments(1a)2.32200.650.353.3
Payments(2a)02.30.650.353.3
Budget lineCommitments(1b)
Payments(2b)
Appropriations of an administrative nature financed from the envelope of specific programmes23
Budget line(3)
TOTAL appropriations
for DG TAXUD
Commitments=1a+1b +32.300.650.353.3
Payments=2a+2b

+3
02.30.650.353.3

Heading of multiannual financial
framework
7‘Administrative expenditure’

This section should be filled in using the 'budget data of an administrative nature' to be firstly introduced in the Annex to the Legislative Financial Statement (Annex 5 to the Commission decision on the internal rules for the implementation of the Commission section of the general budget of the European Union), which is uploaded to DECIDE for interservice consultation purposes.

EUR million (to three decimal places)

Year 2024Year
2025
Year
2026
Year
2027
TOTAL
DG: TAXUD
□ Human resources0.7120.7120.5340.5342.492
□ Other administrative expenditure0.0050.0050.0030.0020.015
TOTAL DG TAXUDAppropriations0.7170.7170.5370.5362.507

EUR million (to three decimal places)

3.2.2. Estimated output funded with operational appropriations

Commitment appropriations in EUR million (to three decimal places)

Indicate objectives and outputsYear 2024Year
2025
Year
2026
Year
2027
TOTAL
Type24

Average costNoCostNoCostNoCostNoCostTotal NoTotal cost
SPECIFIC OBJECTIVE No 125
Specifications0.50.5
Development1.01.0
Maintenance0.20.10.3
Support0.30.350.150.8
Training0.40.4
ITSM – Infrastructure0.10.10.10.3
ITSM - hosting
ITSM - licences
Subtotal for specific objective No 10.02.30.650.353.3
TOTALS0.02.30.650.353.3

3.2.3. Summary of estimated impact on administrative appropriations

-  The proposal/initiative does not require the use of appropriations of an administrative nature

- ☒ The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:

EUR million (to three decimal places)

Year
202426
Year
2025
Year
2026
Year
2027
TOTAL
HEADING 7
of the multiannual financial framework
Human resources0.7120.7120.5340.5342.492
Other administrative expenditure0.0050.0050.0030.0020.015
Subtotal HEADING 7
of the multiannual financial framework
0.7170.7170.5370.5362.507

Outside HEADING 727
of the multiannual financial framework

Human resources
Other expenditure
of an administrative nature
Subtotal
outside HEADING 7
of the multiannual financial framework

TOTAL0.7170.7170.5370.5362.507

The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from the DG that are already assigned to management of the action and/or have been redeployed within the DG, together if necessary with any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary constraints.

3.2.3.1. Estimated requirements of human resources

-  The proposal/initiative does not require the use of human resources.

- ☒The proposal/initiative requires the use of human resources, as explained below:

Estimate to be expressed in full time equivalent units
Year
2024
Year
2025
Year 2026Year 2027
20 01 02 01 (Headquarters and Commission’s Representation Offices)4433
20 01 02 03 (Delegations)
01 01 01 01 (Indirect research)
01 01 01 11 (Direct research)
Other budget lines (specify)
20 02 01 (AC, END, INT from the ‘global envelope’)
20 02 03 (AC, AL, END, INT and JPD in the delegations)
XX 01 xx yy zz 28

- at Headquarters

- in Delegations
01 01 01 02 (AC, END, INT - Indirect research)
01 01 01 12 (AC, END, INT - Direct research)
Other budget lines (specify)
TOTAL4433
XX is the policy area or budget title concerned.

The human resources required will be met by staff from the DG who are already assigned to management of the action and/or have been redeployed within the DG, together if necessary with any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary constraints.

Description of tasks to be carried out:

Officials and temporary staff3 additional AD staff needed for the reparation of meetings and correspondence with Member States, work on implementing regulation, IT formats.

Staff request is additional to the currently existing TAXUD workforce. Proper operationalization of the Council Directive 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (the Pillar Two Directive) is of utmost importance for the functioning of the internal market as well as for the competitiveness of the EU. Furthermore it will bring significant burden reductions for the MNE groups in scope.

This work is also included in the mission letter of Commissioner designate responsible for taxation, namely to work with Member States on the implementation of the global agreement on international tax reform, which introduces a minimum effective tax rate for multinational enterprises active in the EU

New responsibilities steming from this legislation can not be covered with existing staff. Given that this is an ongoing task, the work will continue beyond 2027.
External staffN/A

3.2.4. Compatibility with the current multiannual financial framework

The proposal/initiative:

- ☒ can be fully financed through redeployment within the relevant heading of the Multiannual Financial Framework (MFF).

This proposal will be financed from redeployment of funds from the edisting Fiscalis programme 2024-2027.

-  requires use of the unallocated margin under the relevant heading of the MFF and/or use of the special instruments as defined in the MFF Regulation.

Explain what is required, specifying the headings and budget lines concerned, the corresponding amounts, and the instruments proposed to be used.

-  requires a revision of the MFF.

Explain what is required, specifying the headings and budget lines concerned and the corresponding amounts.

3.2.5. Third-party contributions

The proposal/initiative:

- ☒ does not provide for co-financing by third parties

-  provides for the co-financing by third parties estimated below:

Appropriations in EUR million (to three decimal places)

Year
N29
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)Total
Specify the co-financing body
TOTAL appropriations co-financed

3.3. Estimated impact on revenue

- ☒ The proposal/initiative has no financial impact on revenue.

-  The proposal/initiative has the following financial impact:



-  on own resources

-  on other revenue

- please indicate, if the revenue is assigned to expenditure lines ◻

EUR million (to three decimal places)

Budget revenue line:Appropriations available for the current financial yearImpact of the proposal/initiative30
Year
N
Year
N+1
Year
N+2
Year
N+3
Enter as many years as necessary to show the duration of the impact (see point 1.6)
Article ………….

For assigned revenue, specify the budget expenditure line(s) affected.

Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).

1OJ L 328, 22.12.2022, p. 1–58 ELI: http://data.europa.eu/eli/dir/2022/2523/oj. http://data.europa.eu/eli/dir/2022/2523/oj

2OECD (2023), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (Pillar Two), OECD Publishing, Paris, https://doi.org/10.1787/91a49ec3-en.

3Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1–88 ELI: http://data.europa.eu/eli/reg/2016/679/oj).

4Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39–98 ELI: http://data.europa.eu/eli/reg/2018/1725/oj).

5COM(2023) 168 final.

6OJ C , , p. .

7OJ C , , p. .

8Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (OJ L 328, 22.12.2022, p. 1–58 ELI: http://data.europa.eu/eli/dir/2022/2523/oj).

9Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC (OJ L 64, 11.3.2011, p.1, ELI: http://data.europa.eu/eli/dir/2011/16/oj).

10OECD (2021), Tax Challenges Arising from Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/782bac33-en.

11OECD (2023), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (Pillar Two), OECD Publishing, Paris, https://doi.org/10.1787/91a49ec3-en.

12Ibid.

13OJ L 123, 12.5.2016, p. 1, ELI: http://data.europa.eu/eli/agree_interinstit/2016/512/oj.

14As referred to in Article 58(2)(a) or (b) of the Financial Regulation.

15Regulation (EC) No 1073/1999 of the European Parliament and of the Council of 25 May 1999 concerning investigations conducted by the European Anti-Fraud Office (OLAF), OJ L 136 p. 1, 31.5.1999.

16Council Regulation (Euratom, EC) No 2185/96 of 11 November 1996 concerning on-the-spot checks and inspections carried out by the Commission in order to protect the European Communities' financial interests against fraud and other irregularities, OJ L 292 p. 2, 15.11.96.

17Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations.

18EFTA: European Free Trade Association.

19Candidate countries and, where applicable, potential candidates from the Western Balkans.

20Year N is the year in which implementation of the proposal/initiative starts. Please replace "N" by the expected first year of implementation (for instance: 2021). The same for the following years.

21According to the official budget nomenclature.

22Procurement will start in 2024 with delivery target date of 31. 12. 2025

23Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

24Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.).

25As described in point 1.4.2. ‘Specific objective(s)…’

26Year N is the year in which implementation of the proposal/initiative starts. Please replace "N" by the expected first year of implementation (for instance: 2021). The same for the following years.

27Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.

28Sub-ceiling for external staff covered by operational appropriations (former ‘BA’ lines).

29Year N is the year in which implementation of the proposal/initiative starts. Please replace "N" by the expected first year of implementation (for instance: 2021). The same for the following years.

30As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20 % for collection costs.

EN EN