### 1. member states shall ensure that a taxpayer is able to deduct from its taxable base for corporate income tax purposes exceeding borrowing costs as defined in article 1 , point (2) , of council directive (eu) 2016/116435 up to an amount (a) corresponding to 85% of such costs incurred during the tax period. if such amount is higher than the amount (b) determined in accordance with article 4 of directive (eu) 2016/1164 , member states shall ensure that the taxpayer be entitled to deduct only the lower of the two amounts in the tax period. the difference between the two amounts (a) and (b) shall be carried forward or back in accordance with article 4 of directive (eu) 2016/1164. ### 1. member states shall ensure that a taxpayer is able to deduct from its taxable base for corporate income tax purposes exceeding borrowing costs as defined in article 1 , point (2) , of council directive (eu) 2016/116435 up to an amount (a) corresponding to 50% of such costs incurred during the tax period. if such amount is higher than the amount (b) determined in accordance with article 4 of directive (eu) 2016/1164 , member states shall ensure that the taxpayer be entitled to deduct only the lower of the two amounts in the tax period.


### 2. member states may defer the application of the provisions of this directive to taxpayers that on [1 january 2024] benefit from an allowance on equity under national law for a period up to 10 years and in no case for a period longer than the duration of the benefit under national law. ### deleted


### (8) the commission should exercise its implementing powers only in situations where it assesses that the cessation of a benchmark may result in negative consequences that produce significant disruption in the functioning of financial markets in the union. the commission should also exercise its implementing powers only where it has become clear that the representativeness of the benchmark concerned cannot be restored or that the benchmark will no longer be published on a permanent basis. ### (8) the commission should exercise its implementing powers only in situations where it assesses that the cessation of a benchmark may result in negative consequences that produce significant disruption in the functioning of financial markets and the real economy in the union entailing potential risks of socialisation of private losses. the commission should also exercise its implementing powers only where it has become clear that the representativeness of the benchmark concerned cannot be restored or that the benchmark will no longer be published on a permanent basis.


### (1) the commission may designate a replacement benchmark for a benchmark that will cease to be published where the cessation of that publication may result in significant disruption in the functioning of financial markets in the union and provided that any of the following events has occurred: ### (1) the commission may designate a replacement benchmark for a benchmark that will cease to be published where the cessation of that publication may result in significant disruption in the functioning of financial markets and the real economy in the union and provided that any of the following events has occurred:


### — having regard to articles 127(1) and (2) , 130 and 284(3) of the treaty on the functioning of the european union (tfeu) , ### — having regard to articles 127(1) and (2) , 130 and 284(3) of the treaty on the functioning of the european union (tfeu) and article 3 of the treaty of the european union (teu) ,


### — having regard to the monetary dialogues with the president of the european central bank , christine lagarde , of 6 february and 8 june 2020 , ### — having regard to the monetary dialogues with the president of the european central bank , christine lagarde , of 6 february , 8 june and 28 september 2020 ,


### a. whereas the commission’s summer 2020 economic forecast , taking into account economic shocks caused by the covid-19 pandemic , projects that the euro area economy will contract by 8.7 % in 2020 and grow by 6.1 % in 2021 , and the eu-27 economy will contract by 8.3 % in 2020 and grow by 5.8 % in 2021; ### a. whereas the commission’s summer 2020 economic forecast , taking into account economic shocks caused by the covid-19 pandemic , projects that the euro area economy will contract by 8.7 % in 2020 and grow by 6.1 % in 2021 , and the eu-27 economy will contract by 8.3 % in 2020 and grow by 5.8 % in 2021; whereas the contraction in 2020 is , therefore , projected to be significantly greater and with wider divergences than initially projected; whereas growth in 2020 will be less robust than initially projected;


### b. whereas , according to the eurosystem staff macroeconomic projections of june 2020 , annual inflation for the euro area in the harmonised index of consumer prices (hicp) will be 0.3 % in 2020 , 0.8 % in 2021 and 1.3 % in 2022; ### b. whereas , according to the eurosystem staff macroeconomic projections of september 2020 , annual inflation for the euro area in the harmonised index of consumer prices (hicp) will be 0.3 % in 2020 , 1.0 % in 2021 and 1.3 % in 2022;


### 2. is concerned about the unprecedented healthcare and economic crisis caused by the covid-19 pandemic , with a sharp contraction of the euro area economy and rapidly deteriorating labour market conditions; notes that euro area activity is expected to rebound , although the speed and scale of the rebound remains highly uncertain; ### 2. is deeply concerned about the unprecedented healthcare , social and economic crisis caused by the covid-19 pandemic , with a sharp contraction of the euro area economy and rapidly deteriorating labour market conditions; notes that euro area activity is expected to rebound , although the speed and scale of the rebound remains highly uncertain;


### 6. acknowledges president lagarde’s strong call for ‘full alignment of fiscal and monetary policies’; ### 6. acknowledges president lagarde’s strong call for ‘full alignment of fiscal and monetary policies’ , to ‘rethink and reset’ the numerical ceilings in the stability and growth pact and to ‘explore every avenue available in order to combat climate change’;


### 8. stresses that monetary policy alone will not suffice to achieve a sustainable economic recovery; emphasises that far-reaching structural reforms and initiatives are necessary to restore and enhance competitiveness across the union; believes that the impact of monetary policy on the recovery is limited and , while respecting the independence and mandate of the ecb , expresses caution regarding the further expansion of monetary measures; ### 8. stresses that monetary policy alone will not suffice to achieve a sustainable economic and social recovery; emphasises that far-reaching reforms , investments and initiatives are necessary to restore and enhance sustainability and competitiveness across the union;


### 9. notes the importance of active monetary policy in alleviating the pressure of financial constraints on small and medium-sized enterprises; acknowledges that the percentage of smes facing financial constraints decreased from 18 % in 2009-12 to 8 % in 2016-19; ### 9. notes the importance of active monetary policy in alleviating the pressure of financial constraints on small and medium-sized enterprises; acknowledges that the percentage of smes facing financial constraints decreased from 18 % in 2009-12 to 8 % in 2016-19; stresses , however , that these percentages have increased considerably due to the covid-19 crisis;


### 14. notes the impact of climate change on inflation dynamics and transmission risks in monetary policy; recalls the impact of the ecb in maintaining price stability; emphasises that this mandate must not be confounded with climate policy; ### 14. notes the impact of climate change on inflation dynamics and transmission risks in monetary policy; recalls the impact of the ecb in maintaining price stability; emphasises that this mandate must go hand in hand with climate policy;


### 15. notes that the purchases of green bonds and their share of the ecb’s portfolio continue to increase; ### 15. notes that the purchases of green bonds and their share of the ecb’s portfolio continue to increase , even though remaining relatively small; calls on the ecb to complement the eu’s climate efforts by increasing its purchase of eib-issued green bonds , given the eib commitments to align all its operations with the paris agreement by end 2020 , end financing for fossil fuel energy projects from the end of 2021 and dedicate 50 % of its support to climate action and environmental sustainability by 2025;


### 16. encourages efforts to increase research capabilities regarding the impact of climate change on financial stability and the euro area; ### 16. encourages efforts to increase research capabilities regarding the impact of climate change on financial stability and the euro area and the way that central banking can contribute to an inclusive and sustainable economy and the fight against climate change; calls on the ecb to conduct a study investigating the alignment of the app with the eu taxonomy regulation , with a particular focus on the corporate sector purchase programme (cspp) and corporate asset purchases under the pandemic emergency purchase programme (pepp);


### 17. calls on the ecb to continue its efforts to ensure the stability of financial markets for all possible contingencies related to brexit; ### 17. calls on the ecb to continue its efforts to ensure the stability of financial markets for all possible contingencies related to brexit; calls on the ecb to evaluate the progress achieved in key pieces of eu financial legislation connected to brexit contingencies , such as emir ii , and to take all necessary measures in order to minimise the negative consequences of brexit , especially for regions and countries directly influenced;


### accountability ### transparency and accountability


### 26. welcomes the detailed , section-by-section and substantial feedback provided by the ecb to parliament’ resolution on the 2018 ecb annual report; calls on the ecb to continue this commitment to accountability and to keep on publishing its written feedback to parliament’s resolutions on the ecb annual report each year; ### 26. welcomes the detailed , section-by-section and substantial feedback provided by the ecb to parliament’ resolution on the 2018 ecb annual report; calls on the ecb to continue and further enhance this commitment to accountability and to keep on publishing its written feedback to parliament’s resolutions on the ecb annual report each year;


### 27. recalls the german federal constitutional court decision of 5 may 2020 on the ecb , as well as the ecb governing council statement of the same day; notes the continuous proportionality assessment of all programmes; lauds the ecb’s subsequent decision to disclose non-public documents related to the public sector purchase programme (pspp) to the bundesbank; ### 27. recalls the german federal constitutional court decision of 5 may 2020 on the ecb , as well as the ecb governing council statement of the same day; considers that the gfcc decision , although not affecting the ability of the ecb and the escb to continue the implementation of the pspp , puts in question the role and the attributions of the court of justice in the architecture of the european union; recalls the judgment of the court of justice of the european union of 11 december 2018 , ruling that the pspp does not exceed the ecb’s mandate and does not contravene the prohibition of monetary financing; notes the continuous proportionality assessment of all programmes; lauds the ecb’s subsequent decision to disclose non-public documents related to the public sector purchase programme (pspp) to the bundesbank;


### 28. acknowledges , and congratulates the ecb and president lagarde on , the ongoing efforts to improve communication and transparency with the european parliament; ### 28. acknowledges the ongoing efforts to improve communication and transparency with the european parliament; calls for these efforts to be further intensified;


### a. whereas digital finance is a consistently evolving area of the financial sector which deserves ongoing monitoring and consideration both on an industry and regulatory level; ### a. whereas digital finance is a consistently evolving and booming area of the financial sector which needs ongoing monitoring and consideration both on an industry and regulatory level;


### i. whereas experts of the european central bank (ecb) noted in their publication of 20193 , that even though crypto-assets are highly speculative , they do not represent an immediate threat to financial stability; ### deleted


### j. whereas digital finance can contribute in a number of ways to tackling the economic effects of the covid-19 outbreak as regards consequences for citizens , smes and other businesses and financial services; ### deleted


### 2. considers that fintech will be integral to the success of the capital markets union (cmu) and encourages the commission to consider how to harness the benefits of fintech in driving forward capital market integration in the union; ### 2. expresses serious concerns over the role that fintech will play in the context of the capital markets union (cmu) and encourages the commission to consider the risks of this emerging sector;


### 7. points out that union level measures should not stifle opportunities for businesses to grow and develop within the union; ### deleted


### defining a framework for crypto-assets ### defining a regulatory framework for crypto-assets


### 9. considers that developing a pan-european taxonomy for crypto-assets is desirable as a step towards fostering a common understanding , facilitating collaboration across jurisdictions and providing greater regulatory certainty for market participants engaged in cross border activity; recommends taking into account the importance of international cooperation and global initiatives as regards frameworks for crypto-assets , bearing in mind in particular their borderless nature; cautions , however , that developing an open-ended taxonomy template may be more appropriate for this evolving market segment; ### 9. considers that the crypto-assets sector must be subject to robust regulation and recommends the commission to take into account the importance of international cooperation and global initiatives as regards frameworks for crypto-assets , bearing in mind in particular their borderless nature; notes the speculative nature of various crypto-assets and the financial risks that arise from lack of regulation; calls for a repeal of cryptocurrencies;


### 10. believes , therefore , that any further categorisation should be balanced and flexible in order to give space for innovation in the sector while ensuring that risks can be identified at an early stage; ### 10. believes , therefore , that any further categorisation should be balanced in order to ensure that risks can be identified at an early stage;


### 14. points out that with the increasing digitalisation of financial services , as well as outsourcing to external it solution or maintenance providers , such as cloud providers , the exposure of financial institutions and markets to disruption caused by internal failures or external attacks is becoming more pronounced; ### 14. points out that with the increasing digitalisation of financial services , as well as outsourcing to external it solution or maintenance providers , such as cloud providers , the exposure of financial institutions and markets to disruption caused by internal failures or external attacks is becoming more pronounced; is concerned about the growing shadow banking sector in europe , which includes investment funds , money market funds , fintechs and other financial intermediaries , given the fact that current banking regulations do not apply to these institutions; stresses that shadow banking is characterised by liquidity and maturity mismatches; high leverage; lack of regulation and lack of access to public backstops;


### 15. calls on the commission to propose legislative changes in the area of ict and cyber security requirements for the union financial sector in order to address any inconsistencies , gaps and loopholes that are found to exist in relevant law; ### 15. calls on the commission to propose legislative changes in the area of ict and cyber security requirements for the union financial sector in order to address existing inconsistencies , gaps and loopholes in relevant law , particularly when it comes to consumer data protection;


### a. modernisation; ### a. modernisation and compliance with international standards regarding risk assessment and reporting;


### 18. recalls that the collection and analysis of data play a central role for fintech , and therefore highlights the need for consistent , technology-neutral application of existing data laws; ### 18. recalls that the collection and analysis of data play a central role for fintech , and therefore highlights the need for consistent application of existing data laws;


### 2. to ensure that digital finance can continue to be an innovative driver of growth and jobs across the single market; ### 2. to ensure that digital finance does not pose any systemic threats to the economy;


### 3. to foster a common understanding of the key issues concerning digital finance and encourage the harmonisation of relevant provisions , which will lead to enhanced cross border activity; ### 3. to foster a common understanding of the key issues concerning digital finance and encourage the harmonisation of relevant provisions , in order to increase financial stability in the eu;


### 2. to make a legislative proposal on cyber resilience , which ensures consistent standards of ict security across the union financial sector. such a framework should be future-oriented and focus on modernising the current rules applicable concerning cyber resilience , while also closing any regulatory loopholes and gaps , which may put businesses , investors and consumers at risk; ### 2. to make a legislative proposal on cyber resilience , which ensures consistent standards of ict security across the union financial sector. such a framework should be future-oriented and focus on modernising the current rules applicable concerning cyber resilience , while also closing any regulatory loopholes and gaps , which may put taxpayers , businesses , investors and consumers at risk;


### (13) in march 2020 , the group of central bank governors and heads of supervision (ghos) has revised the implementation timeline of the final elements of the basel framework. whilst most of the final elements still need to be implemented in union law , the leverage ratio buffer requirement for global systemically important institutions has already been implemented through the amendments brought by regulation (eu) 2019/876. therefore , the date of application for the leverage ratio buffer requirement should be deferred by one year to 1 january 2023 , as agreed internationally. the date of application set in regulation (eu) 2019/876 should be revised accordingly in order to ensure a level playing field internationally for institutions established in the union and operating outside the union. with the application of the leverage ratio buffer requirement postponed , during the postponement period there would be no consequences for the failure to meet that requirement as set out in article 141c of directive 2013/36/eu and no related restriction on distributions set out in article 141b of that directive. ### (13) in march 2020 , the group of central bank governors and heads of supervision (ghos) has revised the implementation timeline of the final elements of the basel framework. whilst most of the final elements still need to be implemented in union law , the leverage ratio buffer requirement for global systemically important institutions has already been implemented through the amendments brought by regulation (eu) 2019/876. the date of application set in regulation (eu)2019/876 should be revised accordingly in order to ensure a level playing field internationally for institutions established in the union and operating outside the union.


### (16) the prudential treatment of certain software assets has been amended by regulation (eu) 2019/876 in order to further support the transition towards a more digitalised banking sector. in the context of the accelerated up-take of digital services as a consequences of public measures adopted to address the covid-19 pandemic , the application of these changes should be anticipated. ### deleted


### (18) for the extraordinary support measures adopted to alleviate the impact of the covid-19 pandemic to be fully effective with regard to keeping the banking sector more resilient and providing an incentive to the institutions to continue lending , it is necessary for the alleviating effect of those measures to be immediately reflected in the way in which regulatory capital requirements are determined. having regard to the urgency of those adjustments to the prudential framework , this regulation should enter into force on the day following that of its publication in the official journal of the european union. ### (18) for the extraordinary support measures adopted to alleviate the impact of the covid-19 pandemic to be fully effective with regard to keeping the banking sector more resilient and providing an incentive to the institutions to continue lending , it is necessary for the alleviating effect of those measures to be immediately reflected in the way in which regulatory capital requirements are determined. institutions that benefit from any relief and capital conservation measures should , however , not be allowed to make any distributions to shareholders (dividends , buy-backs , at1 coupons) and discretionary payments to staff (bonuses). having regard to the urgency of those adjustments to the prudential framework , this regulation should enter into force on the day following that of its publication in the official journal of the european union.


### in paragraph 1 , point (j) is replaced by the following: ### deleted


### paragraph 4 is deleted; ### deleted


### [...] ### deleted


### (10) in article 58 , paragraph 2 is replaced by the following: ### deleted


### the purpose is to describe the most material risks that are specific to the issuer and the shares. ### a description of the material risks that are specific to the issuer and that may affect the issuer’s ability to fulfil its obligations under the securities , in a limited number of categories , in a section headed ‘risk factors’. in each category the most material risks , in the assessment of the issuer , offeror or person asking for admission to trading on a regulated market , taking into account the negative impact on the issuer and the probability of their occurrence , shall be set out first. the risk factors shall be corroborated by the content of the registration document. also , an assessment of systemic risk must be presented.


### b. whereas the actions taken so far to achieve the cmu are moving in the right direction; whereas much work nevertheless remains to be done in terms of the precision , effectiveness and simplification of the measures adopted; ### deleted


### c. whereas the social and economic crisis resulting from covid-19 will have a particularly negative impact on smes and retail savers; whereas the eu’s response to covid-19 through the european recovery plan should provide a large injection of capital in order to increase european enterprises’ access to finance; ### c. whereas the social and economic crisis resulting from covid-19 will have a particularly negative impact on smes and retail savers; whereas the eu’s response to covid-19 through the european recovery plan should guarantee european enterprises’ access to finance in order to preserve jobs and countries’ productive capacity;


### 1. calls for the removal of barriers , including the simplification of legislation , to diversify funding sources for smes , in order to promote smes’ ability to access equity markets , and to reduce the existing debt bias; points out that the current situation makes smes more fragile and vulnerable; ### 1. takes note of the existing debt bias in corporate financing; points out that the empirical evidence and the academic literature are not conclusive as to whether the current situation makes smes more fragile; points out that market-based finance is associated with significant risks;


### 2. takes the view that the efficiency of financial markets should be improved and that the listing of companies should be facilitated; encourages the creation and prioritisation of a large private pan-european fund , an initial public offering (ipo) fund , to support smes; ### 2. takes the view that the efficiency and stability of financial markets should be improved and that the listing of companies should be facilitated; encourages the creation and prioritisation of a large private pan-european fund , an initial public offering (ipo) fund , to support smes;


### 3. calls for the acceleration of the development of eu venture capital (vc) and private equity markets by increasing the availability of funding for vc investments , developing larger late-stage vc funds , tax incentive schemes for vc and business angel investments , and active ipo markets for vc-backed companies; ### deleted


### 5. calls for targeted measures within securities market legislation to expedite the recovery after the covid-19 crisis; supports changes in the prospectus regulation , the markets in financial instruments directive (mifid) , the securitisation regulation and the market abuse regulation to facilitate investments in the real economy , in particular in smes , and to allow newcomers and new products to enter the markets , preserving consumer protection and market integrity; ### 5. stresses that the existing regulations must be complied with by member-states (namely , the prospectus regulation , the markets in financial instruments directive (mifid) , the securitisation regulation and the market abuse regulation); calls for a strengthened enforcement of the regulation regarding consumer protection and market integrity;


### 6. asks the member states to amend their national tax frameworks , in order to reduce tax obstacles to cross-border investments , including withholding tax procedures , and to increase financing by investors to long-term investment opportunities thereby improving returns on long-term savings for eu citizens; ### 6. asks the member states to increase financing by investors to long-term investment opportunities;


### 8. stresses the necessity of advancing further in the implementation of a genuinely single rule book for financial services in the internal market; ### 8. stresses the necessity of advancing further in the implementation of a genuinely single rule book for financial services in the internal market , particularly in the field of taxation; calls for the establishment of a financial transactions tax at eu level;


### 9. underlines the need to promote pension provision; welcomes the pan-european personal pension (pepp) product; reminds member states that pepps need to be subject to the same tax treatment as national pension products to become an option for savers; ### 9. underlines that private pension provision , such as the pan-european personal pension (pepp) product , is inherently risky and can leave people with no protection in times of financial distress , as has happened in the last months; stresses that pepps should not be subject to the same tax treatment as national pension products;


### 10. encourages the member states to promote multi-pillar pension systems , including occupational pension schemes , as a way to improve market dynamics and the incentives to invest; believes that private pensions should be revitalised and made more attractive; encourages the participation of investors in long-term products with tax reduction or exemption policies; ### 10. believes that private pensions should not be encouraged by the state and should not benefit from any tax exemption or fiscal benefits;


### 12. stresses the need for european and national supervisory authorities to overcome their differences; calls for supervisory convergence to promote a common european model , guided by the european securities and market authority (esma) , to reduce the existing obstacles to cross-border financial operations; ### 12. calls for supervisory convergence to promote a common european model , guided by the european securities and market authority (esma) , provided that no existing regulations are watered down;


### 13. observes that financial services regulation is a very complex undertaking , with regulation at international , european and national level; encourages all relevant actors to address this complexity to ensure the proportionality of financial regulation and to remove unnecessary administrative burdens; ### 13. observes that financial services regulation is a very complex undertaking , with regulation at international , european and national level; encourages all relevant actors to address this complexity to ensure the proportionality of financial regulation;


### 14. is concerned that retail investors’ engagement with financial markets remains low; calls for measures to promote retail investments in view of the demographic challenges faced by the eu by increasing the participation of retail investors in capital markets through more attractive and appropriate personal pension products; ### 14. notes that retail investors’ engagement with financial markets remains low;


### 18. is of the opinion that the current reporting framework within mifid ii and the european market infrastructure regulation (emir) is very costly and complex , hindering the effectiveness of the system; believes that a simplification thereof is necessary; ### deleted


### 20. underlines that financial education is needed to overcome low retail investor engagement with financial markets , based on lack of knowledge , mistrust and risk aversion; ### 20. underlines that financial education is needed to guarantee that consumers know their rights and the risks associated with financial market participation;


### 22. urges the member states to include financial literacy programs in school curricula aimed at developing autonomy in financial matters; suggests the inclusion of this topic in the programme for international student assessment (pisa) study; ### 22. urges the member states to include financial literacy programs in school curricula aimed at developing autonomy in financial matters;


### 23. takes the view that the digitalisation of financial services can be a catalyst for the mobilisation of capital in the eu while reducing barriers and increasing supervisory efficiency; emphasises that an eu framework with high standards of cybersecurity would be conducive to the cmu; ### 23. emphasises that an eu framework with high standards of cybersecurity would be an important step;


### (8) due to the significant volume of information and its sensitivity in terms of the protection of personal data , it is necessary and proportionate that payment service providers retain records of the information in relation to cross-border payment transactions for a two-year period in order to assist member states fight e-commerce vat fraud and detect fraudsters. this period constitutes the minimum necessary for member states to carry out controls effectively and to investigate suspected vat fraud or to detect vat fraud. ### (8) due to the significant volume of information and its sensitivity in terms of the protection of personal data , it is necessary and proportionate that payment service providers retain records of the information in relation to cross-border payment transactions for a five-year period in order to assist member states fight e-commerce vat fraud and detect fraudsters. this period constitutes the minimum necessary for member states to carry out controls effectively and to investigate suspected vat fraud or to detect vat fraud.


### be kept by the payment service provider in electronic format for a period of two years from the end of the year during which the payment transaction was executed; ### be kept by the payment service provider in electronic format for a period of five years from the end of the year during which the payment transaction was executed;


### (13) it is necessary and proportionate that payment service providers retain records of the information in relation to payment transactions for a two-years period to assist member states fight e-commerce vat fraud and detect fraudsters. this period constitute the minimum necessary for member states to carry out controls effectively and investigate into suspected vat fraud or detect vat fraud , and it is proportionate considering the massive volume of the payment information and its sensitivity in terms of protection of personal data. ### (13) it is necessary and proportionate that payment service providers retain records of the information in relation to payment transactions for a five-year period to assist member states fight e-commerce vat fraud and detect fraudsters. this period constitutes the minimum necessary for member states to carry out controls effectively and investigate into suspected vat fraud or detect vat fraud , and it is proportionate considering the massive volume of the payment information and its sensitivity in terms of protection of personal data.


### 2. cesop shall retain the information referred to in points (a) and (b) of paragraph 1 for a maximum period of two years from the expiry of the year when the information was transferred into the system. ### 2. cesop shall retain the information referred to in points (a) to (c) of paragraph 1 for a maximum period of five years from the expiry of the year when the information was transferred into the system.


### a. whereas according to the commission’s summer 2019 economic forecast , the latest figures of 2019 reflect a slowdown from the higher levels of gdp growth in the euro area in 2018 , from 1.9 % to 1.2 % in 2019 , and in the eu-27 , from 2.1 % in 2018 to 1.4 % in 2019 , owing to a weaker impetus from external trade uncertainties; ### a. whereas according to the commission’s summer 2019 economic forecast , the latest figures of 2019 reflect a slowdown from the higher levels of gdp growth in the euro area in 2018 , from 1.9 % to 1.2 % in 2019 , and in the eu-27 , from 2.1 % in 2018 to 1.4 % in 2019 , owing to a weaker impetus from external trade uncertainties and to the brexit;


### b. whereas according to eurostat figures , the unemployment rate in august 2019 stood at 6.2 % in the eu and 7.4 % in the euro area , the lowest rates since july 2008; ### b. whereas according to eurostat figures , the unemployment rate in august 2019 stood at 6.2 % in the eu and 7.4 % in the euro area , the lowest rates since july 2008 , with youth unemployment rate more than double the average rate and with extraordinary regional inequalities in unemployment within and among member states;


### 2. is concerned that after a short economic recovery , euro area growth momentum has slowed markedly to 1.2 % of gdp in the euro area and to 1.4 % of gdp for the eu-27; underlines , therefore , the need for monetary policy to remain accommodative for the foreseeable future; ### 2. is concerned that after a short economic recovery , euro area growth momentum has slowed markedly to 1.2 % of gdp in the euro area and to 1.4 % of gdp for the eu-27; underlines , therefore , the need for monetary policy to remain accommodative for the foreseeable future; is also concerned by the decreasing growth in industrial production and world trade and the unpreparedness , as mr. draghi underlined , of the european economic governance framework to prevent and possibly deal with a looming new economic and financial crisis;


### 9. underlines that very low or negative interest rates offer opportunities to consumers , workers and borrowers , who can benefit from stronger economic momentum , lower unemployment and lower borrowing costs; ### 9. underlines that very low or negative interest rates , despite some short-term positive effects , do not work sufficiently well in offering opportunities to all consumers , workers and borrowers , as the richest of the population are the ones more likely to benefit from lower borrowing costs thus boosting wealth inequality;


### 11. recalls that , as an eu institution , the ecb is bound by the paris agreement on climate change and that this should be reflected in its policies , with full respect for its mandate and its independence; ### 11. recalls that , as an eu institution , the ecb is bound by the paris agreement on climate change and that this should be reflected in its policies , with full respect for its mandate and its independence; believes that environmental protection should be prioritised among the secondary objectives of the ecb as specified in art. 127 tfeu and art. 3 teu;


### 13. calls on the ecb to continue its preparatory efforts to ensure the stability of eu financial markets for all possible contingencies relating to brexit; ### 13. calls on the ecb to continue its preparatory efforts to ensure the stability of eu financial markets for all possible contingencies relating to brexit; calls on the ecb to evaluate the progress achieved in key pieces of eu financial legislation connected to brexit contingencies , such as emir ii , and to take all necessary measures in order to minimise the negative consequences of brexit , especially for regions and countries directly influenced;


### 18. agrees with christine lagarde that a review of the ecb’s monetary policy framework is timely and warranted in order to ensure that the ecb has the right tools to deliver on its price stability mandate in the future; calls on the ecb to organise a public consultation as part of this process in order to ensure that the review is open to input and feedback from a broad range of diverse civil society stakeholders; ### 18. agrees with christine lagarde that a review of the ecb’s monetary policy framework is timely and warranted in order to ensure that the ecb has the right tools to deliver on its price stability mandate in the future; calls on the ecb to organise a public consultation as part of this process in order to ensure that the review is open to input and feedback from a broad range of diverse civil society stakeholders; tasks econ committee to carry out its own-initiative report on the topic;


### 19. welcomes the increase in accountability under the presidency of mario draghi , and looks forward to even greater accountability , dialogue and openness with the incoming president; ### 19. welcomes the increase in accountability under the presidency of mario draghi and looks forward to even greater transparency , accountability , dialogue and openness with the incoming president by improving , inter alia , the setup of the monetary dialogue , taking into account other national parliament models and the feedback provided by the monetary experts commissioned by econ in march 2014; regrets that mrs. lagarde failed to participate in the european parliament for the plenary discussion and approval of her appointment;


### 21. welcomes the substantial , detailed , section-by-section feedback provided by the ecb on parliament’s resolution on the 2017 ecb annual report; calls on the ecb to continue this commitment to accountability and to continue publishing its written feedback on parliament’s resolution on the ecb annual report each year; ### 21. welcomes the substantial , detailed , section-by-section feedback provided by the ecb on parliament’s resolution on the 2017 ecb annual report; calls on the ecb to continue and further enhance this commitment to accountability and to continue publishing its written feedback on parliament’s resolution on the ecb annual report each year;


### 7. welcomes the participation on an equal footing of all countries involved in the inclusive framework , which brings together over 130 countries and jurisdictions to collaborate on the implementation of the oecd/g20 beps package and to negotiate joint solutions for tackling the remaining beps challenges; recalls , however , that over 100 developing countries were excluded from the negotiations on the 15 beps actions; ### 7. welcomes the participation on an equal footing of all countries involved in the inclusive framework , which brings together over 130 countries and jurisdictions to collaborate on the implementation of the oecd/g20 beps package and to negotiate joint solutions for tackling the remaining beps challenges; recalls , however , that over 100 developing countries were excluded from the negotiations on the 15 beps actions; supports the creation of an intergovernmental un tax body to lead in a fairer way international negotiations on tax rules , as requested by the 130 countries of the g77;


### 8. notes that the oecd preliminary findings of the impact assessment suggest that the combined effect of pillar one and pillar two would lead to a significant increase in global tax revenues as well as a redistribution on taxing rights to market jurisdictions; notes in particular that pillar two would yield a significant increase of corporate income tax revenue globally; understands the two pillars would not adversely affect the investment environment; ### 8. notes that the oecd preliminary findings of the impact assessment suggest that the combined effect of pillar one and pillar two would lead to a significant increase in global tax revenues as well as a redistribution on taxing rights to market jurisdictions; notes in particular that pillar two would yield a significant increase of corporate income tax revenue globally; however , points out that a study from the tax justice network estimated that only 5% of the profits currently declared in tax havens would be redistributed and would mostly benefit the high income countries; recommends that the oecd conducts an impact assessment of different versions of the proposal and includes the distribution by country of new tax revenues; understands the two pillars would not adversely affect the investment environment;


### 12. considers that the scope of the reform should cover all large firms having the possibility to engage in beps practices by exploiting legal loopholes; ### 12. considers that the scope of the reform should cover all large firms having the possibility to engage in beps practices by exploiting legal loopholes; points out having a higher threshold of 750 million will leave out of the scope of the reform most large firms operating in the internal market; recommends the oecd to align its definition of a large firm with the european definition of 40 million turnover as specified by the accounting directive 2013/34/eu;


### 16. welcomes the idea that this new nexus would be a stand-alone provision to ensure no need to revise all tax treaties; ### 16. notes the idea that this new nexus would be a stand-alone provision to ensure no need to revise all tax treaties as a first step; however , reaffirms the need to revise the current definition of permanent establishment;


### 20. welcomes the willingness to ensure tax certainty and to limit dispute that could arise from the implementation of the new nexus and the new allocation of taxing rights; ### 20. notes the willingness to ensure tax certainty and to limit dispute that could arise from the implementation of the new nexus and the new allocation of taxing rights; however , points out the reform should not develop arbitration mechanisms to avoid weakening the existing national and international legal system , by fuelling a parallel system of arbitration;


### 26. reminds that setting a global level for minimum effective taxation raises the questions of blending across jurisdictions; considers therefore that , with respect to the income inclusion rule , the minimum effective level of taxation should be established for each jurisdiction where the mnes are located to limit possibilities to continue engaging in aggressive tax planning; ### 26. reminds that setting a global level for minimum effective taxation raises the questions of blending across jurisdictions; considers therefore that , with respect to the income inclusion rule , a minimum effective level of taxation should be established for each jurisdiction where the mnes are located and each entity or subsidiary to limit possibilities to continue engaging in aggressive tax planning;


### 30. strongly encourages the commission and the member states to achieve a deal at international level which would then be transposed at eu level through relevant eu and national legislations; likewise supports the commitment of the commission president-elect to propose an eu solution , should an international deal not be reached by the end of 2020; ### 30. strongly encourages the commission and the member states to achieve a deal at international level which would then be transposed at eu level through relevant eu and national legislations; likewise supports the commitment of the commission president-elect to propose an eu solution , should an international deal not be reached by the end of 2020 to the condition this eu solution is not limited to digital businesses;


### 31. invites the council , with the support of the commission , to update the criteria of the eu list of non-cooperative jurisdictions for tax purposes once the international rules and/or the eu newly agreed reforms have been adopted , and notably the eu listing criteria on fair taxation; ### 31. invites the council , with the support of the commission , to urgently update the criteria of the eu list of non-cooperative jurisdictions for tax purposes and without waiting for the international rules and/or the eu newly agreed reforms to be adopted , and notably the eu listing criteria on fair taxation;


### a. whereas the process of deepening the economic and monetary union requires a solid banking union as an indispensable building block to the euro area’s financial stability , as well as the creation of a mechanism of fiscal stabilisation for the euro area as a whole; ### a. whereas a healthy banking system is a prerequisite for economic growth and financial stability;


### c. whereas entrusting the ecb with the supervision of systemically important financial institutions has proven to be successful; ### deleted


### d. whereas the development of the single resolution mechanism (srm) was efficient; ### d. whereas the development of the single resolution mechanism (srm) was a useful but not yet completed instrument to avoid the socialisation of losses;


### 1. market data contributors shall , with regard to shares , etfs and bonds that are traded on a trading venue , and with regard to otc derivatives as defined in article 2(7) of regulation (eu) no 648/2012 that are subject to the clearing obligation as referred to in article 4 of that regulation , provide the ctp with all the market data as set out in article 22b(2) as needed for the ctp to be operational. those market data shall be provided in a harmonised format , through a high quality transmission protocol , and as close to real-time as is technically possible. ### 1. all the market data contributors shall , with regard to shares , etfs and bonds that are traded on a trading venue , and with regard to otc derivatives as defined in article 2(7) of regulation (eu) no 648/2012 that are subject to the clearing obligation as referred to in article 4 of that regulation , provide the ctp with all the market data as set out in article 22b(2) as needed for the ctp to be operational. those market data shall be provided in a harmonised format , through a high quality transmission protocol , and as close to real-time as is technically possible.


### the level of the fees that the applicant intends to charge to the different types of users of the core market data; ### deleted


### collect monthly subscription fees from users; ### collect monthly subscription fees from professional investors , but guarantee free use for retails investors;


### article 39a ### article 39a


### investment firms acting on behalf of clients shall not receive any fee or commission or non-monetary benefits from any third party for forwarding client orders to such third party for their execution.; ### 1. investment firms acting on behalf of clients shall not receive any fee or commission or non-monetary benefits from any third party for forwarding client orders to such third party for their execution;


### (7) dark trading is trading without pre-trade transparency , using the reference price waiver laid down in article 4(1) , point (a) of regulation (eu) no 600/2014 and the negotiated trade waiver laid down in article 4(a) point (a) , point (i) of that regulation. the use of both waivers is capped by the double volume cap (‘dvc’). the dvc is a mechanism that limits the level of dark trading to a certain proportion of total trading in an equity instrument. the amount of dark trading in an equity instrument on an individual venue may not exceed 4% of total trading in that instrument in the union. when this threshold is breached , dark trading in that instrument on that venue is suspended. secondly the amount of dark trading in an equity instrument in the union may not exceed 8% of total trading in that instrument in the union. when this threshold is breached all dark trading in that instrument is suspended. the venue specific threshold leaves room for continued use of those waivers on other platforms on which trading in that equity instrument is not yet suspended , until the union wide threshold is breached. this causes complexity in terms of monitoring the levels of dark trading and of enforcing the suspension. to simplify the double volume cap while keeping its effectiveness , the new single volume cap should rely solely on the eu-wide threshold. that threshold should be lowered to 7 % to compensate for a potential increase of trading under those waivers as a consequence of abolishing the venue specific threshold. ### (7) dark trading is trading without pre-trade transparency , using the reference price waiver laid down in article 4(1) , point (a) of regulation (eu) no 600/2014 and the negotiated trade waiver laid down in article 4(a) point (a) , point (i) of that regulation. the use of both waivers is capped by the double volume cap (‘dvc’). the dvc is a mechanism that limits the level of dark trading to a certain proportion of total trading in an equity instrument. the amount of dark trading in an equity instrument on an individual venue may not exceed 4% of total trading in that instrument in the union. when this threshold is breached , dark trading in that instrument on that venue is suspended. secondly the amount of dark trading in an equity instrument in the union may not exceed 8% of total trading in that instrument in the union. when this threshold is breached all dark trading in that instrument is suspended. the venue specific threshold leaves room for continued use of those waivers on other platforms on which trading in that equity instrument is not yet suspended , until the union wide threshold is breached. this causes complexity in terms of monitoring the levels of dark trading and of enforcing the suspension. to simplify the double volume cap while keeping its effectiveness , the new single volume cap should rely solely on the eu-wide threshold. that threshold should be lowered to 5 % to compensate for a potential increase of trading under those waivers as a consequence of abolishing the venue specific threshold.


### (35) ‘consolidated tape provider’ or ‘ctp’ means a person authorised in accordance with title iva , chapter 1 of this regulation to provide the service of collecting market data for shares , etfs , bonds or derivatives , from market data contributors , and of consolidating those data into a continuous electronic live data stream providing core market data per share , etf , bond or derivatives and of providing them to user of market data;; ### (35) ‘consolidated tape provider’ or ‘ctp’ means a person authorised in accordance with title iva , chapter 1 of this regulation to provide the service of collecting market data for shares , etfs , bonds or derivatives , from market data contributors , and of consolidating those data into a continuous electronic live data stream providing core market data per share , etf , bond or derivatives and of providing them to user of market data , guarantying the quality of the data , it’s free access to retail investors and in a user-friendly way ;


### 1. trading venues shall suspend their use of the waivers referred to in article 4(1) , point (a) , and 4(1) , point (b)(i) where the percentage of volume traded in the union in a financial instrument carried out under those waivers exceeds 7% of the total volume traded in that financial instrument in the union. trading venues shall base their decision to suspend the use of those waivers on the data published by esma in accordance with paragraph 4 , and shall take such decision within two working days after this publication of those data and for a period of six months.; ### 1. trading venues shall suspend their use of the waivers referred to in article 4(1) , point (a) , and 4(1) , point (b)(i) where the percentage of volume traded in the union in a financial instrument carried out under those waivers exceeds 5% of the total volume traded in that financial instrument in the union and upon order of esma after the data published in accordance with paragraph 4;


### 4. esma shall publish within five working days of the end of each calendar month all of the following data: ### 4. esma shall publish within four working days of the end of each calendar month all of the following data:


### based on the deferral regime as set out in paragraph 4 , competent authorities shall authorise market operators and investment firms operating a trading venue to defer the publication of the price of transactions until the end of the trading day , or the volume of transactions for a maximum of two weeks.; ### based on the deferral regime as set out in paragraph 4 , only competent authorities can authorise market operators and investment firms operating a trading venue to defer the publication of the price of transactions until the end of the trading day , or the volume of transactions for a maximum of one week;


### (6) it would be fair to exclude from the envisaged rules undertakings whose activities are subject to an adequate level of transparency and therefore do not present a risk of lacking substance for tax purposes. companies having a transferable security admitted to trading or listed on a regulated market or multilateral trading facility as well as certain financial undertakings which are heavily regulated in the union , directly or indirectly , and subject to increased transparency requirements and supervision , should equally be excluded from the scope of this directive. pure holding undertakings which are situated in the same jurisdiction as the operational subsidiary and their beneficial owner(s) are not likely to serve the objective of obtaining a tax advantage either. similar is the case of sub-holding undertakings which are situated in the same jurisdiction as their shareholder or ultimate parent entity. on this basis , they should also be excluded. undertakings that engage an adequate number of persons , full-time and exclusively , in order to carry out their activities should equally not be considered to lack minimal substance. while they are not reasonably expected to pass the gateway criterion , they should be excluded explicitly for purposes of legal certainty. ### deleted


### (13) to ensure effectiveness of the proposed framework , it is necessary to establish appropriate tax consequences for undertakings that do not have minimal substance for tax purposes. undertakings that have crossed the gateway criterion and are presumed to be lacking substance for tax purposes while , additionally , have not provided evidence to the contrary or evidence that they do not serve the objective of obtaining a tax advantage , should not be allowed to benefit from the provisions of agreements and conventions that provide for the elimination of double taxation of income , and where applicable , capital , to which the member state of their tax residence is a party and from any other agreements , including provisions in international agreements for the promotion and protection of investments , with equivalent purpose or effect. such undertakings should not be allowed to benefit from council directive 2011/96/eu14 and council directive 2003/49/ec15. to this effect , those undertakings should not be entitled to a certificate of tax residence to the extent that this serves to obtain those benefits. the member state where the undertaking is resident for tax purposes should therefore deny to issue a certificate of tax residence. alternatively , that member state should be able to issue such certificate while indicating , by means of a warning , that it should not be used by the undertaking to obtain tax benefits as above. this denial of a certificate of tax residence , or alternatively the issue of a special certificate of tax residence , should not set aside the national rules of the member state of the undertaking with regard to the tax residence and relevant obligations linked thereto. it would rather serve to communicate to other member states , and third countries , that no relief or refund should be granted with regard to transactions involving this undertaking based on any treaty with the member state of the undertaking or union directives , if applicable. ### (13) to ensure effectiveness of the proposed framework , it is necessary to establish appropriate tax consequences for undertakings that do not have minimal substance for tax purposes. undertakings that have crossed the gateway criterion and are presumed to be lacking substance for tax purposes while , additionally , have not provided evidence to the contrary or evidence that they do not serve the objective of obtaining a tax advantage , should be denied the certificate of tax residence from the member state where the undertaking is residence.


### (13) to ensure effectiveness of the proposed framework , it is necessary to establish appropriate tax consequences for undertakings that do not have minimal substance for tax purposes. undertakings that have crossed the gateway criterion and are presumed to be lacking substance for tax purposes while , additionally , have not provided evidence to the contrary or evidence that they do not serve the objective of obtaining a tax advantage , should not be allowed to benefit from the provisions of agreements and conventions that provide for the elimination of double taxation of income , and where applicable , capital , to which the member state of their tax residence is a party and from any other agreements , including provisions in international agreements for the promotion and protection of investments , with equivalent purpose or effect. such undertakings should not be allowed to benefit from council directive 2011/96/eu14 and council directive 2003/49/ec15 . to this effect , those undertakings should not be entitled to a certificate of tax residence to the extent that this serves to obtain those benefits. the member state where the undertaking is resident for tax purposes should therefore deny to issue a certificate of tax residence. alternatively , that member state should be able to issue such certificate while indicating , by means of a warning , that it should not be used by the undertaking to obtain tax benefits as above. this denial of a certificate of tax residence , or alternatively the issue of a special certificate of tax residence , should not set aside the national rules of the member state of the undertaking with regard to the tax residence and relevant obligations linked thereto. it would rather serve to communicate to other member states , and third countries , that no relief or refund should be granted with regard to transactions involving this undertaking based on any treaty with the member state of the undertaking or union directives , if applicable. ### (13) to ensure effectiveness of the proposed framework , it is necessary to establish appropriate tax consequences for undertakings that do not have minimal substance for tax purposes. undertakings that have crossed the gateway criterion and are presumed to be lacking substance for tax purposes while , additionally , have not provided evidence to the contrary or evidence that they do not serve the objective of obtaining a tax advantage , should not be allowed to benefit from the provisions of agreements and conventions that provide for the elimination of double taxation of income , and where applicable , capital , to which the member state of their tax residence is a party and from any other agreements , including provisions in international agreements for the promotion and protection of investments , with equivalent purpose or effect. such undertakings should not be allowed to benefit from council directive 2011/96/eu14 and council directive 2003/49/ec15 . to this effect , those undertakings should not be entitled to a certificate of tax residence to the extent that this serves to obtain those benefits. the member state where the undertaking is resident for tax purposes should therefore deny to issue a certificate of tax residence. alternatively , that member state should be able to issue such certificate while indicating , by means of a warning , that it should not be used by the undertaking to obtain tax benefits as above or to participate in public tenders in the member state. this denial of a certificate of tax residence , or alternatively the issue of a special certificate of tax residence , should not set aside the national rules of the member state of the undertaking with regard to the tax residence and relevant obligations linked thereto. it would rather serve to communicate to other member states , and third countries , that no relief or refund should be granted with regard to transactions involving this undertaking based on any treaty with the member state of the undertaking or union directives , if applicable.


### (5) ‘beneficial owner’ means beneficial owner as defined in article 3 , point (6) , of directive (eu) 2015/849 of the european parliament and of the council; ### (5) ‘beneficial owner’ for the purpose of this directive means any natural person owning directly or indirectly at least 5% of the share of the undertaking;


### an undertaking which holds assets that can generate income falling within the scope of article 4 , points (e) and (f) , shall also be deemed to meet the criterion set out in point (a) of the first subparagraph , irrespective of whether income from these assets has accrued to the undertaking in the preceding two tax years , if the book value of these assets is more than 75% of the total book value of the undertaking’s assets. ### an undertaking which holds assets that can generate income falling within the scope of article 4 , points (e) and (f) , shall also be deemed to meet the criterion set out in point (a) of the first subparagraph , irrespective of whether income from these assets has accrued to the undertaking in the preceding two tax years , if the book value of these assets is more than 50% of the total book value of the undertaking’s assets.


### an undertaking which holds assets that can generate income falling within the scope of article 4 , point (c) , shall also be deemed to meet the criterion set out in point (a) of the first subparagraph , irrespective of whether income from these assets has accrued to the undertaking in the preceding two tax years , if the book value of these assets is more than 75% of the total book value of the assets of the undertaking. ### an undertaking which holds assets that can generate income falling within the scope of article 4 , point (c) , shall also be deemed to meet the criterion set out in point (a) of the first subparagraph , irrespective of whether income from these assets has accrued to the undertaking in the preceding two tax years , if the book value of these assets is more than 50% of the total book value of the assets of the undertaking.


### [...] ### deleted


### undertakings with at least five own full-time equivalent employees or members of staff exclusively carrying out the activities generating the relevant income; ### deleted


### (ii) the majority of the full-time equivalent employees of the undertaking are resident for tax purposes in the member state of the undertaking , or at no greater distance from that member states insofar as such distance is compatible with the proper performance of their duties , and such employees are qualified to carry out the activities that generate relevant income for the undertaking. ### deleted


### grant a certificate of tax residence which prescribes that the undertaking is not entitled to the benefits of agreements and conventions that provide for the elimination of double taxation of income , and where applicable , capital , and of international agreements with a similar purpose or effect and of articles 4 , 5 and 6 of directive 2011/96/eu and article 1 of directive 2003/49/ec. ### deleted


### grant a certificate of tax residence which prescribes that the undertaking is not entitled to the benefits of agreements and conventions that provide for the elimination of double taxation of income , and where applicable , capital , and of international agreements with a similar purpose or effect and of articles 4 , 5 and 6 of directive 2011/96/eu and article 1 of directive 2003/49/ec. ### grant a certificate of tax residence which prescribes that the undertaking is not entitled to the benefits of agreements and conventions that provide for the elimination of double taxation of income , and where applicable , capital , and of international agreements with a similar purpose or effect and of articles 4 , 5 and 6 of directive 2011/96/eu and article 1 of directive 2003/49/ec and cannot participate in any public tenders in the member state.


### 1. by 31 december 2028 , the commission shall present a report to the european parliament and the council on the implementation of this directive. ### 1. every year from the entry into force of this directive , the commission shall present a report to the european parliament and the council on the implementation of this directive.


### i. whereas tax policy is a national competence , but strong cooperation between member states is essential to respond to the challenges posed to the integrity of the single market , namely by the increasing the use of crypto-assets; whereas a framework of 27 significantly different approaches to crypto-assets taxation could lead to significant obstacles for the fulfilment of the objectives of the european digital single market; ### i. whereas tax policy is a national competence , but strong cooperation between member states is essential to respond to the challenges posed to the integrity of the single market , namely by the increasing use of crypto-assets; whereas a framework of 27 significantly different approaches to crypto-assets taxation could lead to harmful tax competition and significant obstacles for efficient tax collection;


### j. whereas the european union and its single market must ensure an innovation-friendly environment for companies (namely small and medium-sized enterprises (smes) and start-ups) regarding new technologies in the area of financial services and crypto-assets; whereas this main goal requires a strong commitment from member states with policies , namely on taxation , that ensure a stable , clear and certain legal framework for businesses to thrive and contribute to economic growth; whereas , finally , this effort requires strong commitment to safeguard citizens’ rights , as taxpayers and consumers of financial services; ### j. whereas the european union and its single market must ensure that it safeguards citizens’ rights , as taxpayers and consumers of financial services;


### 2. points out that adapting the it capacities of tax authorities through new emerging technologies , such as potential distributed ledger technologies like blockchain or artificial intelligence , promises to foster intelligent , effective and efficient tax and administrative procedures , facilitate tax compliance by citizens and businesses , and increase the traceability and identification of taxable transactions in a globalised environment where cross-border transactions have increased; ### 2. points out that adapting the it capacities of tax authorities through new emerging technologies , such as potential distributed ledger technologies like blockchain or artificial intelligence , may foster intelligent , effective and efficient tax and administrative procedures , facilitate tax compliance by citizens and businesses , and increase the traceability and identification of taxable transactions in a globalised environment where cross-border transactions have increased;


### 3. highlights the need to identify the best ways to use technology to strengthen the analytical capacity of tax administrations (through better data analysis) , to standardise data to reduce administrative burdens on smes , to ensure that taxation better reflects the business environment in the digital age and at the same time guarantees high levels of data protection; ### 3. highlights the need to identify the best ways to use technology to strengthen the analytical capacity of tax administrations (through better data analysis) and at the same time guarantee high levels of data protection;


### 7. considers that crypto-assets must be subject to fair , transparent and effective taxation , in order to guarantee fair competition between businesses in the area of financial services; understands that decisions on the taxation of crypto-assets lie with member states , according to the treaties; stands for an innovation-friendly environment in the digital single market , where entrepreneurs , smes and start-ups can thrive , generate growth , create jobs and contribute to economic recovery through tax revenues; ### 7. considers that crypto-assets must be subject to effective taxation taking into account their negative externalities where they exist , in order to guarantee fair competition between businesses in the area of financial services;


### 13. calls on the member states to consider the dimension of crypto-assets in their national tax reforms , and to consider implementing more effective systems that ensure less compliance costs and administrative burden , but that guarantee , at the same time , the fair , transparent and effective taxation of crypto-assets; underlines the role of tax incentives and exemptions in promoting technological innovation and development; ### 13. calls on the member states to consider the dimension of crypto-assets in their national tax reforms , and to consider implementing more effective systems that guarantee taxation of crypto-assets taking into account their additional negative externalities; warns against the creation of tax loopholes and the intensification of harmful tax competition by creating tax incentives and exemptions in the name of technological innovativeness;


### 14. points out that the crypto-asset landscape is global and requires an international approach; understands , in this regard , the need to further negotiate international instruments on the matter; ### 14. points out that the crypto-asset landscape is global and requires an international approach; understands , in this regard , the need to further negotiate international instruments on the matter; calls , in this regard for crypto-assets to be included within the scope of the common reporting standard (crs) developed by the oecd in 2014;


### 2. highlights that the statutory independence of the ecb , as laid down in the treaties , is a prerequisite for it to fulfil its mandate; ### 2. highlights that the statutory independence of the ecb , as laid down in the treaties , is an obstacle to a democratic monetary policy; notes that such independence renders the ecb immune to democratic scrutiny , while its single mandate to maintain price stability leads to a recurrent bias towards the interests of financial sector agents;


### 3. welcomes the republic of croatia as the 20th member country of the euro area; ### 3. notes that the republic of croatia is now the 20th member country of the euro area;


### 4. notes that fiscal and monetary policies have reinforced each other during the pandemic; stresses that maintaining price stability today requires even closer coordination between fiscal , monetary and structural policies , as addressing supply-side shocks requires greater supply-chain resilience and a shift away from fossil fuels; ### 4. notes that fiscal and monetary policies have reinforced each other during the pandemic; stresses that maintaining price stability and promoting full employment today requires even closer coordination between fiscal , monetary and structural policies , as addressing supply-side shocks requires significant public and private investments to address supply bottlenecks , promote greater supply-chain resilience and a shift away from fossil fuels;


### 5. welcomes president lagarde’s statement that the current geopolitical crisis requires us to progress on eu fiscal integration; recalls that the economic and monetary union cannot function smoothly without a fiscal capacity at european level to respond to external shocks; ### 5. welcomes president lagarde’s statement that the current geopolitical crisis requires us to progress on eu fiscal integration; recalls that the economic and monetary union cannot function smoothly without sufficient fiscal capacity at european level to respond to external shocks;


### 6. echoes president lagarde’s call for a swift revision and simplification of the stability and growth pact; ### deleted


### 7. is alarmed that euro area inflation has continued to rise and has reached undesirably high levels; stresses that headline inflation rose to a record 9.1 % in august 2022; stresses that energy is by far the most significant driver of inflation (38.3 %) , followed by food prices (10.6 %); ### 7. is concerned that euro area inflation has continued to rise and has reached undesirably high levels; stresses that headline inflation rose to a record 9.1 % in august 2022; stresses that energy is by far the most significant driver of inflation (38.3 %) , followed by food prices (10.6 %);


### 8. takes note of recent ecb monetary policy decisions to raise rates by 50 and 75 basis points in july and september 2022; is concerned about the implications of such policy decisions for growth and employment; ### 8. regrets recent ecb monetary policy decisions to raise rates by 50 and 75 basis points in july and september 2022; is concerned about the implications of such policy decisions for growth and employment; calls on the ecb to revert the rise in interest rates and to take the necessary actions to ensure low interest rates in the euro area;


### 9. observes that there is little evidence that rising inflation is spurring a wage-price spiral , not least given the extent of wage restraint in recent years; ### 9. observes that there is little evidence that rising inflation is spurring a wage-price spiral , not least given the extent of wage restraint and the decline in unionization in recent years; recalls that real wages have been falling substantially over the last months in euro area countries;


### 10. recalls that the ecb strategy review reconfirmed the medium-term orientation of inflation targeting; calls on the ecb to faithfully target this medium-term horizon; ### 10. recalls that the ecb strategy review reconfirmed the medium-term orientation of inflation targeting; regrets that this review did not encompass the definition of a double mandate for the central bank to keep price stability and promote full employment , following the example of comparable economic areas such as the us;


### 12. stresses that an even transmission of monetary policy is vital to the achievement of the ecb’s price stability mandate; notes the ecb’s decision on 15 june 2022 to apply flexibility in reinvesting redemptions that are due under the pandemic emergency purchase programme; welcomes the launch of the transmission protection instrument to support the effective transmission of monetary policy across the euro area; ### 12. stresses that an even transmission of monetary policy is vital to the achievement of the ecb’s price stability mandate; notes the ecb’s decision on15 june 2022 to apply flexibility in reinvesting redemptions that are due under the pandemic emergency purchase programme; takes note of the launch of the transmission protection instrument to support the effective transmission of monetary policy across the euro area; regrets that the use of this instrument is subject to a discretionary evaluation of each member-states public finances by the central bank , as well as to the compliance with current fiscal rules laid down in the sgp , which can have counterproductive effects in terms of debt sustainability;


### 13. notes with concern that the combination of cheap targeted longer-term refinancing operations (tltros) and higher interest rates allow european banks to earn billions in extra profit; regrets the fact that the ecb has not yet addressed this issue; ### 13. notes with concern that the combination of cheap targeted longer-term refinancing operations (tltros) and higher interest rates allow european banks to earn billions in extra profit , which may amount to 24 billion until 20246a;regrets the fact that the ecb has not yet addressed this issue and calls on the central bank to quickly close this loophole;


### secondary objectives ### other objectives


### 15. calls on the ecb to coordinate with the european parliament to specify the secondary objectives; suggests taking advantage of this resolution to specify and prioritise the policy areas where the ecb is expected to deliver on its secondary objectives; ### 15. calls on the ecb to coordinate with the european parliament to specify other equally important objectives , such as the promotion of full employment; suggests taking advantage of this resolution to specify and prioritise the policy areas where the ecb is expected to deliver on these objectives;


### 16. considers high levels of sustainable growth and investment to be key economic goals; calls on the ecb to consider how its monetary policy stance will impact those objectives; ### 16. considers high levels of socially and environmentally sustainable growth and investment to be key economic goals; calls on the ecb to consider how its monetary policy stance will impact those objectives;


### (2) in a continued effort to put an end to tax practices of mnes which allow them to shift profits to jurisdictions where they are subject to no or very low taxation , the oecd has further developed a set of international tax rules to ensure that mnes pay a fair share of tax wherever they operate. this major reform aims to put a floor on competition over corporate income tax rates through the establishment of a global minimum level of taxation. by removing a substantial part of the advantages of shifting profits to jurisdictions with no or very low taxation , the global minimum tax reform will level the playing field for businesses worldwide and allow jurisdictions to better protect their tax bases. ### (2) in a continued effort to put an end to tax practices of mnes which allow them to shift profits to jurisdictions where they are subject to no or very low taxation , the oecd has further developed a set of international tax rules to ensure that mnes pay a fair share of tax wherever they operate. this major reform aims to put a floor on competition over corporate income tax rates through the establishment of a global minimum level of taxation. by removing a substantial part of the advantages of shifting profits to jurisdictions with no or very low taxation , the global minimum tax reform will level the playing field for businesses worldwide and allow jurisdictions to better protect their tax bases. however , a wide scope for tax competition between member states will remain. the minimum tax should not be regarded as an optimal level of corporate taxation and member states should not use this opportunity to lower their corporate taxation levels , either through the nominal rate as increasing allowances.


### (7) while it is necessary to ensure that tax avoidance practices are discouraged , adverse impacts on smaller mnes in the internal market should be avoided. for this purpose , this directive should only apply to entities located in the union that are members of mne groups or large-scale domestic groups that meet the annual threshold of at least eur 750 000 000 of consolidated revenue. this threshold would be consistent with the threshold of existing international tax rules such as the country-by-country reporting rules9 . entities within the scope of this directive are referred to as constituent entities. certain entities should be excluded from the scope based on their particular purpose and status. excluded entities would be those that are not profit-driven and perform activities in the general interest and which are , for these reasons , not likely to be subject to tax in the member state in which they are located. in order to protect those specific interests , it is necessary to exclude from the scope of the directive governmental entities , international organisations , non-profit organisations and pension funds from the scope of this directive. investment funds and real estate investment vehicles should also be excluded from the scope when they are at the top of the ownership chain , since , for those so-called flow-through entities , the income earned is taxed at the level of the owners. ### (7) while it is necessary to ensure that tax avoidance practices are discouraged , adverse impacts on smaller mnes in the internal market should be avoided. for this purpose , this directive should only apply to entities located in the union that are members of mne groups or large-scale domestic groups that meet the annual threshold of at least eur 40 000 000 of consolidated revenue. entities within the scope of this directive are referred to as constituent entities. certain entities should be excluded from the scope based on their particular purpose and status. excluded entities would be those that are not profit-driven and perform activities in the general interest and which are , for these reasons , not likely to be subject to tax in the member state in which they are located. in order to protect those specific interests , it is necessary to exclude from the scope of the directive governmental entities , international organisations and non-profit organisations.


### (12) the etr of an mne group in each jurisdiction where it carries out activities or of a large-scale domestic group should be compared to the agreed minimum tax rate of 15 % in order to determine whether the mne group or large-scale domestic group is liable to pay a top-up tax and consequently should apply the iir or the utpr. the minimum tax rate of 15 % agreed by the oecd/g20 inclusive framework on beps reflects a balance amongst corporate tax rates worldwide. in cases where the etr of an mne group falls below the minimum tax rate in a given jurisdiction , the top-up tax should be allocated to the entities in the mne group that are liable to pay the tax in accordance with the application of the iir and the utpr , in order to comply with the globally agreed minimum effective rate of 15 %. in cases where the etr of a large-scale domestic group falls below the minimum tax rate , the upe at the top of the large-scale domestic group should apply the iir in respect of its low-taxed constituent entities , in order to ensure that such group is liable to pay tax at an effective minimum rate of 15 %. ### (12) the etr of an mne group in each jurisdiction where it carries out activities or of a large-scale domestic group should be compared to the agreed minimum tax rate of 25 % in order to determine whether the mne group or large-scale domestic group is liable to pay a top-up tax and consequently should apply the iir or the utpr. the minimum tax rate of 15 % agreed by the oecd/g20 inclusive framework on beps reflects a minimum standard amongst corporate tax rates worldwide. in cases where the etr of an mne group falls below the minimum tax rate in a given jurisdiction , the top-up tax should be allocated to the entities in the mne group that are liable to pay the tax in accordance with the application of the iir and the utpr , in order to comply with the globally agreed minimum effective rate of 15 % or the minimum effective rate of 25% agreed at union level. in cases where the etr of a large-scale domestic group falls below the minimum tax rate , the upe at the top of the large-scale domestic group should apply the iir in respect of its low-taxed constituent entities , in order to ensure that such group is liable to pay tax at an effective minimum rate of 15 %.


### (12) the etr of an mne group in each jurisdiction where it carries out activities or of a large-scale domestic group should be compared to the agreed minimum tax rate of 15 % in order to determine whether the mne group or large-scale domestic group is liable to pay a top-up tax and consequently should apply the iir or the utpr. the minimum tax rate of 15 % agreed by the oecd/g20 inclusive framework on beps reflects a balance amongst corporate tax rates worldwide. in cases where the etr of an mne group falls below the minimum tax rate in a given jurisdiction , the top-up tax should be allocated to the entities in the mne group that are liable to pay the tax in accordance with the application of the iir and the utpr , in order to comply with the globally agreed minimum effective rate of 15 %. in cases where the etr of a large-scale domestic group falls below the minimum tax rate , the upe at the top of the large-scale domestic group should apply the iir in respect of its low-taxed constituent entities , in order to ensure that such group is liable to pay tax at an effective minimum rate of 15 %. ### (12) the etr of an mne group in each jurisdiction where it carries out activities or of a large-scale domestic group should be compared to the agreed minimum tax rate of 25 % in order to determine whether the mne group or large-scale domestic group is liable to pay a top-up tax and consequently should apply the iir or the utpr. the minimum tax rate of 15 % agreed by the oecd/g20 inclusive framework on beps reflects a balance and a minimum standard amongst corporate tax rates worldwide. in cases where the etr of an mne group falls below the minimum tax rate in a given jurisdiction , the top-up tax should be allocated to the entities in the mne group that are liable to pay the tax in accordance with the application of the iir and the utpr , in order to comply with the globally agreed minimum effective rate of 15 % or the minimum effective rate of 25% agreed at union level. in cases where the etr of a large-scale domestic group falls below the minimum tax rate , the upe at the top of the large-scale domestic group should apply the iir in respect of its low-taxed constituent entities , in order to ensure that such group is liable to pay tax at an effective minimum rate of 15 % as defined by the relevant jurisdiction.


### (13) in order to allow member states to benefit from the top-up tax revenues collected on their low-taxed constituent entities located in their territory , member states should be able to elect to apply a domestic top-up tax system. constituent entities of an mne group that are located in a member state which has elected to implement rules equivalent to the iir and the utpr in their own domestic tax system should pay the top-up tax to this member state. while leaving member states some flexibility in the technical implementation of the domestic top-up tax system , such system should ensure the minimum effective taxation of the qualifying income or loss of the constituent entities in the same , or in an equivalent manner , to the iir and utpr of this directive. ### (13) in order to allow member states to benefit from the top-up tax revenues collected on their low-taxed constituent entities located in their territory , member states should have the option to apply a domestic top-up tax system. constituent entities of an mne group that are located in a member state which has elected to implement rules equivalent to the iir and the utpr in their own domestic tax system should pay the top-up tax to this member state. while leaving member states some flexibility in the technical implementation of the domestic top-up tax system , such system should ensure the minimum effective taxation of the qualifying income or loss of the constituent entities in the same , or in an equivalent manner , to the iir and utpr of this directive. stresses that the creation of the national top up tax ensures an automatic floor on the total tax paid by the companies covered by the current directive and simultaneously places a floor on competition over corporate taxation collected by the source country. however , it does not create a floor on tax competition for companies under the proposed threshold. member states should work with the european institutions in order to establish a roadmap for the upward convergence on corporate taxation in the internal market. furthermore , calls on the european commission to monitor possible national measures that aim to compensate for the potential increase in corporate income tax , making sure that effective taxation level is not lowered.


### (14) to ensure a proportionate approach , this exercise should take into consideration certain specific situations in which beps risks are reduced. therefore , the directive should include a substance carve-out based on the costs associated with employees and the value of tangible assets in a given jurisdiction. this would allow to address , to a certain extent , situations where an mne group or a large-scale domestic group carries out economic activities which require material presence in a low-taxed jurisdiction as in such case beps practices would be unlikely to flourish. the specific case of mne groups that are at the first stages of their international activity should also be considered in order not to discourage the development of cross-border activities for mne groups that benefit from low taxation in their domestic jurisdiction where they are predominantly operating. thus , the low-taxed domestic activities of such groups should be excluded from the application of the rules for a transitional period of five years , and provided that the mne group does not have constituent entities in more than six other jurisdictions. in order to ensure equal treatment for large-scale domestic groups , the income from the activities of such groups should also be excluded for a transitional period of five years. ### deleted


### (15) due to its highly volatile nature and the long economic cycle of this industry , the shipping sector is traditionally subject to alternative or supplementary taxation regimes in member states. to avoid undermining that policy rationale and allow member states to continue applying a specific tax treatment to the shipping sector in line with international practice and state aid rules , shipping income should be excluded from the system. ### deleted


### (16) in order to achieve a balance between the objectives of the global minimum tax reform and the administrative burden for tax administrations and taxpayers , this directive should provide for a de minimis exclusion for mne groups or large-scale domestic groups that have an average revenue of less than eur 10 000 000 and an average qualifying income or loss of less than eur 1 000 000 in a jurisdiction. such mne groups or large-scale domestic groups should not pay a top-up tax even if their etr is below the minimum tax rate in that jurisdiction. ### deleted


### (17) the application of the rules of this directive to mne groups and large-scale domestic groups that fall within its scope for the first time could give rise to distortions resulting from the existence of tax attributes , including losses from prior fiscal years , or from timing differences , and require transitional rules to eliminate such distortions. a gradual decrease of the rates for the payroll and the tangible assets carve-outs over ten years should also apply to allow a smooth transition to the new tax system. ### deleted


### (18) for an efficient application of the system , it is crucial that procedures are coordinated at a group level. it will be necessary to operate a system ensuring the unobstructed flow of information within the mne group and towards tax administrations where constituent entities are located. the primary responsibility of filing the information return should lie on the constituent entity itself. a waiver of such responsibility should however apply where the mne group has designated another entity to file and share the information return. it could be either a local entity or an entity from another jurisdiction that has a competent authority agreement in place with the member state of the constituent entity. in the first twelve-months after its entry into force , the commission should review this directive in line with the agreement reached by the inclusive framework on filing requirements under the globe implementation framework. considering the compliance adjustments that this system requires , groups that fall within the scope of this directive for the first time should be granted a period of 18 months to comply with the information requirements. ### (18) for an efficient application of the system , it is crucial that procedures are coordinated at a group level. it will be necessary to operate a system ensuring the unobstructed flow of information within the mne group and towards tax administrations where constituent entities are located. the primary responsibility of filing the information return should lie on the constituent entity itself. a waiver of such responsibility should however apply where the mne group has designated another entity to file and share the information return. it could be either a local entity or an entity from another jurisdiction that has a competent authority agreement in place with the member state of the constituent entity. in the first twelve-months after its entry into force , the commission should review this directive , via relevant delegated acts , in line with the agreement reached by the inclusive framework on filing requirements under the globe implementation framework. considering the compliance adjustments that this system requires , groups that fall within the scope of this directive for the first time should be granted a period of 18 months to comply with the information requirements.


### 1. this directive shall apply to constituent entities located in the union that are members of an mne group or a large-scale domestic group which has an annual revenue of eur 750 000 000 or more in its consolidated financial statements in at least two of the last four consecutive fiscal years. ### 1. this directive shall apply to constituent entities located in the union that are members of an mne group or a large-scale domestic group which has an annual revenue of eur 40 000 000 or more in its consolidated financial statements in at least two of the last four consecutive fiscal years. each member state may apply an income inclusion rule in accordance with this directive also to mne groups which have annual revenues above a nationally defined lower threshold if the ultimate parent entity is tax resident in this member state. the same threshold shall then apply to large-scale domestic groups of this member state.


### a governmental entity , an international organisation , a non-profit organisation , a pension fund , an investment entity that is an ultimate parent entity and a real estate investment vehicle that is an ultimate parent entity; or ### a governmental entity , an international organisation and a non-profit organisation that is an ultimate parent entity;


### an entity that is owned at a minimum of 95 % by one or more entities referred to in point (a) , directly or through several such entities , except pension services entities , and that: ### deleted


### an entity that is owned at a minimum of 85 % by one or more entities referred to in point (a) , directly or through one or several such entities , provided that substantially all of its income is derived from dividends or equity gains or losses that are excluded from the computation of the qualifying income in accordance with point (b) of article 15(2). ### deleted


### a refundable tax credit designed in such a way that it is payable as a cash payment or a cash equivalent to a constituent entity within four years from the date when the constituent entity is entitled to receive the refundable tax credit under the laws of the jurisdiction granting the credit; or ### a refundable tax credit designed in such a way that it is payable as a cash payment or a cash equivalent to a constituent entity within two years from the date when the constituent entity is entitled to receive the refundable tax credit under the laws of the jurisdiction granting the credit; or


### [...] ### deleted


### 7. a deferred tax liability that is not paid or reversed within the five subsequent fiscal years shall be recaptured to the extent it was taken into account in the total deferred tax adjustment amount of a constituent entity. ### 7. a deferred tax liability that is not paid or reversed within the three subsequent fiscal years shall be recaptured to the extent it was taken into account in the total deferred tax adjustment amount of a constituent entity.


### the amount of the recaptured deferred tax liability determined for the fiscal year shall be treated as a reduction to the covered tax of the fifth preceding fiscal year and the effective tax rate and top-up tax of such fiscal year shall be recomputed in accordance with article 28(1). ### the amount of the recaptured deferred tax liability determined for the fiscal year shall be treated as a reduction to the covered tax of the third preceding fiscal year and the effective tax rate and top-up tax of such fiscal year shall be recomputed in accordance with article 28(1).


### research and development expenses; ### deleted