INCREASE IN CORPORATE TAXATION IN EUROPE
In 2026, Europe is experiencing a combination of two key factors that affect the tax burden for corporations:– first, the implementation of the global minimum tax rate (Pillar Two) and the inherent consequences of its application;– second, national tax decisions of individual states that directly change or revise tax rates and tax bases in 2026.Together, this creates a new reality for multinational groups and local companies, forcing them to reconsider tax planning, reporting, and cash flow.Why is 2026 important?While countries have been gradually implementing the OECD rules regarding Pillar Two, the end of 2025 and the beginning of 2026 became a critical period — many jurisdictions have already adopted or are preparing legislative changes that effectively “increase” the minimum tax base for large MNE groups (threshold ≈ €750 million). Pillar Two introduces a global minimum effective tax rate of 15%, and the mechanisms (IIR, UTPR, and QDMTT) create the basis for collecting a “top-up” tax where the actual ETR is lower than 15%. This changes the approach to profit location and to the calculation of the effective tax rate in each jurisdiction.Pillar Two: short and...