COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL A Fair and Efficient Tax System in the European Union for the Digital Single Market
Date: 2017-09-21
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: corporation tax, digital technology, international tax law, single market, tax harmonisation, tax system

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 21.9.2017  COM(2017) 547 final   COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL A Fair and Efficient Tax System in the European Union for the Digital Single Market  
 
 
Introduction  

The Digital Single Market (DSM) is one of the 10 political priorities of the European Commission. The 
DSM strategy1 aims to open up digital opportunities for people and businesses in a market of over 
500 million EU consumers.  Completing the Digital Single Market could contribute to EUR 415 billion 
per  year  to  Europe's  economy,  create  jobs  and  transform  our  public  services.  In  the  18  months 
following  the  adoption  of  the  DSM  Strategy,  the  European  Commission  delivered  the  announced 
proposals. In the mid-term review of the strategy 2 it has updated its analysis and focused on the next 
series of challenges. Digital technologies are transforming our world and having an important impact 
on  taxation  systems.  They  help  improving  their  management,  offering  solutions  to  reduce 
administrative  burdens,  facilitate  collaboration  between  tax  authorities,  and  address  tax  evasion. 
However,  they  transform  business  models,  with  intangibles  playing  an  increasingly  important  role, 
putting pressure on Europe's taxation system. 

The EU Digital Single Market needs a modern and  stable tax framework for the digital economy to 
stimulate innovation, tackle market fragmentation and allow all players to tap into the new market 
dynamics  under  fair  and  balanced  conditions.  It  is  essential  to  ensure  tax  certainty  for  business 
investment and to prevent new tax loopholes emerging in the Single Market.   

In the field of taxation, policy makers are struggling to find solutions which would ensure fair and 
effective taxation as the digital transformation of the economy accelerates. There are weaknesses 
in the international tax rules as they were originally designed for "brick and mortar" businesses and 
have  now  become  outdated.  The  current  tax  rules  no  longer  fit  the  modern  context  where 
businesses  rely  heavily  on  hard-to-value  intangible  assets,  data  and  automation,  which  facilitate 
online trading across borders with no physical presence. These issues are not confined to the digital 
economy  and  potentially  impact  all  businesses.  As  a  result,  some  businesses  are  present  in  some 
countries  where  they  offer  services  to  consumers  and  conclude  contracts  with  them,  taking  full 
advantage of the infrastructure and rule of law institutions available while they are not considered 
present  for  tax  purposes.  This  free  rider  position  tilts  the  playing  field  in  their  favour  compared  to 
established businesses. 

As a result, the growing challenge of ensuring that the digital economy is fairly taxed has still not 
been  adequately  addressed,  primarily  due  to  a  lack  of  international  consensus  and  the 
multidimensional  nature  of  the  challenge.  This  is  an  unsustainable  situation  in  an  increasingly 
globalised and digitally connected world, where ever more activity is moving into the digital space. 
Failure  to  address  these  situations  will  lead  to  more  opportunities  for  tax  avoidance,  less  tax 
revenues  for  public  budgets,  impact  on  social  fairness,  including  through  erosion  of  the  social 
budgets,  and  it  will  destabilise  the  level  playing  field  for  businesses.  This  puts  at  risk  EU 
competitiveness,  fair  taxation  and  the  sustainability  of  Member  States'  budgets.  As  Commission 
President  Jean-Claude  Juncker  emphasised  it  in  his  2017  State  of  the  Union  Address3,  the 
Commission  calls  for  fair  taxes  for  the  digital  industry.  In  the  Informal  ECOFIN  in  Tallinn4,  the 

1  COM(2015) 192 
2  COM(2017) 228 
3 http://europa.eu/rapid/press-release_SPEECH-17-3165_en.htm 
4 https://www.eu2017.ee/political-meetings/ECOFIN 

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Presidency  supported  by  a  large  number  of  Member  States  called  on  the  Commission  to  explore 
options and propose effective solutions, with a view to agree on a way forward for the EU by the end 
of the year.  

Since  the  start  of  its  mandate,  this  Commission  has  taken  action  to  ensure  the  principle  that  all 
businesses operating in the EU should pay their taxes where profits and value are generated. This 
principle is essential for a fair and effective taxation in the Single Market, and it can only be enforced 
through  common  and  coordinated  measures.  Divergent  national  approaches  within  the  EU  can 
fragment the Single Market, increase tax uncertainty, destabilise the level playing field and open new 
loopholes  for  tax  abuse.  As  already  identified  in  the  Commission's  report  in  May  20145,  the 
international tax framework needs to  be reformed  so that it effectively captures the value created 
from the new business models – unfortunately, it has so far proved difficult to agree on the solutions 
at global level, as is evident from the OECD report in October 20156. The time to act has now come. 
The Commission wants an ambitious EU agenda on the matter and a common EU approach to ensure 
that the digital economy is taxed effectively and in a way that ensures fairness and supports growth. 

This new agenda will complement the major strides that have already been made in improving the 
corporate  tax  framework  in  recent  years,  both  at  EU  and  international  level.  Within  the  EU, 
Member States have agreed to a series of ambitious new rules to tackle aggressive tax planning and 
increase  tax  transparency,  and  have  intensified  their  international  stance  on  tax  good  governance 
through the External Strategy on Effective Taxation. In the area of State aid control, the Commission 
has carried out a general enquiry into the tax ruling practices of Member States and is investigating 
tax rulings and schemes that grant preferential tax treatment to some companies.  The Commission 
has  ordered  the  recovery  of  aid  in  several  cases.  In  the  area  of  Value-Added  Tax  (VAT),  the 
Commission is also addressing head on the challenges posed by the digital economy with its proposal 
on  e-commerce7.  Negotiations  are  advancing  on  the  Common  Consolidated  Corporate  Tax  Base 
(CCCTB)8, which was re-launched by the Commission in 2016. Once agreed, the CCCTB will provide a 
competitive, fair and robust framework for taxing companies in the Single Market.   

Businesses are now more digitalised than ever before 

We  are  acting  in  a  borderless  and  globalised  world.  Increased  consumption  is  accompanied  by 
intensified trade and increasing trade volumes. At the same time trade becomes more international. 
The  growth  of  the  digital  economy  is  leading  to  a  revolution  in  everyday  life  and  business  models, 
which  are  not only  affecting traditional  economic,  political,  governance, enforcement and  business 
models but also tax and customs administration.  

Digitalisation  has  acted  as  a  facilitator  and  accelerator  of  cross-border  trade.  The  evolution  of 
business models means that companies operate in a fundamentally different manner today than at 
the time the international tax and customs rules were designed – for example, no physical presence 
is required to sell goods and services into a market, which means that it can be difficult to establish 

5 See European Commission Expert Group on Taxation of the Digital Economy Report, May 2014. 
6 See Addressing the Tax Challenges of the Digital Economy, OECD Base Erosion and Profit Shifting Project 
Action 1 Report, October 2015. 
7 COM(2016)757 
8 COM(2016)683 and COM(2016)685 

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the tax base in the market jurisdiction or the origin of goods for customs purposes. From one click on 
the computer, one can order from all over the world. This translates into new market reach, overall 
lower  prices  and  new  opportunities.  It  is  disrupting  existing  business  models,  and  online  platforms 
are more effectively reacting to demand. It is relevant that this not only results in an increase in trade 
but also in a fragmentation of trade, involving new parties that are not always familiar with tax and 
customs  obligations,  or  perhaps  can  structure  their  business  in  such  a  way  as  to  bypass  these 
obligations.  

Digitalisation  changes  the  nature  of  exchange  by  blurring  the  lines  between  goods  and  services, 
transforming products to their digital representation, such as e-books, or using the least material 
possible,  for  example  3D  printing.  The  economy  is  becoming  increasingly  digitalised  so  existing 
business models will need to adapt to this new reality as the new business models emerge. The main 
characteristics of these new business models are the ability to conduct activity remotely, volatility in 
the  market  (e.g.  the  rapid  gaining  and  losing  of  market  share),  tendency  towards  monopoly  or 
oligopoly, and network effects, to name just a few9.   

The  digitalisation  of  the  global  economy  is  happening  at  a  fast  pace  and  large  scale,  permeating 
almost all areas of society. Close to a third of the growth of the overall industrial output in Europe is 
already due to the uptake of digital technologies10. In 2006 only one technology company was among 
the  top  20,  accounting  for  only  7%  of  the  market  capitalisation.  In  2017,  9  out  of  the  top  20 
companies by market capitalisation were technology companies, accounting for 54% of the total top 
20 market capitalisation11. Between 2008 and 2016, revenue by the top 5 e-commerce retailers grew 
on average by 32% per year. During the same time period, revenue in the entire EU retail sector grew 
on average by 1% per year12. New advances will rapidly arise from a new generation of information 
technologies,  such  as  internet  of  things,  artificial  intelligence,  robotics  and  virtual  reality.  Digital 
solutions are increasingly used and open up new opportunities for people, businesses, investors and 
public 
is 
administrations. 
essential that EU businesses grasp 
these  opportunities  to  remain 
competitive,  and  that  EU  start-
ups  are  able  to  scale  up  quickly, 
with  full  use  of  cloud  computing, 
big  data  solutions,  robotics  and 
speed  broadband.  The 
high 
challenge  ahead  is  for  Europe  to 
seize  swiftly  all 
these  digital 
opportunities  to  ensure  Europe's 
competitiveness,  while  ensuring 
fair taxation.  

It 

9 See Addressing the Tax Challenges of the Digital Economy, OECD Base Erosion and Profit Shifting Project 
Action 1 Report, October 2015. 
10  COM(2016) 180 
11 Global Top 100 Companies by market capitalisation' PWC, 2017; Financial Times Global 500 database, 2006.  
12 Bloomberg and Eurostat databases, accessed on 13 September 2017.  

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Digitalisation affects all businesses, but to varying degrees. A challenge for tax policy is the diversity 
of  business  models  enabled  through  technology  and  exploitation  of  large  amounts  of  data. 
Customers  are  able  to  purchase  goods  and  services  from  anywhere  in  the  world  via  the  internet 
rather  than  the  local  high  street.  New  generations  of  consumers  favour  instant  access  over 
ownership.  Asset-light  digital  platforms  connect  spare  capacity  and  demand,  and  facilitate  huge 
amounts  of  collaborative  transactions,  which  are  forecast  to  grow  by  35%  per  year  over  the  next 
decade13. Businesses of all kinds now derive much of their value from intangible assets, information 
and data. There is no single defining feature of new ways of doing business in the digital space and 
the different aspects are often combined together in a single business. This diversity requires work 
on the scoping of the various types of digital activities and services to be covered by any potential 
solution.  A  non-exhaustive  list  is  presented  below  to  highlight  some  of  the  new  ways  of  doing 
business in the digital economy, which give rise to the issues of "Where to tax?" and "What to tax?". 
These new paradigms require new policy responses. 

Examples of new ways of doing business  

  Online retailer model, whereby online platforms sell goods or connect buyers and sellers in 
return for a transaction or placement fee or a commission. Examples of businesses include 
Amazon, Zalando, Alibaba. 

  Social media model, whereby network owners rely on advertising revenues by delivering 

targeted marketing messages to consumers. Examples of businesses include Facebook, Xing, 
Qzone. 

  Subscription model, whereby platforms charge subscription fee for continued access to a digital 

services (e.g. music or videos). Examples of businesses include Netflix, Spotify, iQiyi. 

  Collaborative platform model, whereby digital platforms connect spare capacity and demand, 

use reputational currency mechanisms to underpin consumption, and enable individuals to share 
“access” to assets rather than own them outright. Platforms charge a fixed or variable fee on 
each transaction. Examples of businesses include Airbnb, Blablacar, Didi Chuxing. 

13 See Literature review on taxation, entrepreneurship and collaborative economy - final report by Dondena & 
IHS, study commissioned by the European Commission, forthcoming. 

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The  EU  needs  a  modern  tax  framework  to  seize  digital  opportunities,  while  also  ensuring  fair 
taxation. A level playing field is a pre-condition for all businesses to be able to innovate, develop and 
grow  to  support  higher  levels  of  productivity,  employment  and  prosperity.  However,  the  level  of 
digitalisation  varies across sectors, particularly between high tech areas and more traditional ones, 
and between Member States and regions. There are also large disparities between large companies 
and  SMEs.  On average,  domestic  digitalised business  models  are  subject  to  an  effective  tax  rate  of 
only 8.5%, less than half compared to traditional business models14 (see graph below). This is mainly 
due to the characteristics of digitalised business models, which rely heavily on intangible assets and 
benefit  from  tax  incentives.  Cross  border  digitalised  businesses  benefit  from  a  similarly  low  tax 
burden,  even  without accounting  for  aggressive  cross-border tax planning that  can  bring down  the 
tax burden to effectively zero15.  

Source: Digital Tax Index, 2017, PWC and ZEW  

Critical challenges  

The main challenge is to reform the international tax framework, which was first designed at the 
start of the twentieth century and is no longer fit for purpose. This has worked well for traditional 
"brick and mortar" companies but as business activities have become more globalised and digitalised 
the old rules work less well.  

14 See Digital Tax Index, PWC and ZEW, 2017. Traditional business model: assets are assumed to be equally 
divided between buildings, machinery, inventory, financial assets and intangible assets. Digital business model 
is the average over three different models ('domestic', 'B2C', 'B2B'). The basic assumption for all three is that 
assets are equally divided between acquired intangibles, self-created intangibles, IT hardware, acquired 
software, self-created software. The B2C and B2B models use subsidiaries to organise their sales and marketing 
activities. 
15 See 'The Impact of Tax-planning on Forward-looking Effective Tax Rates' by ZEW, Taxation paper 64, DG 
TAXUD, European Commission. 

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The  underlying  principle  for  corporation  tax  is  that  profits  should  be  taxed  where  the  value  is 
created.  However,  in  a  digitalised  world,  it  is  not  always  very  clear  what  that  value  is,  how  to 
measure it, or where it is created. 

The two main policy challenges that need to be addressed can be summarised as follows: 

-  Where to tax? (nexus) – how to establish and protect taxing rights in a country where businesses 
can  provide  services  digitally  with  little  or  no  physical  presence  despite  having  a  commercial 
presence; and  

-  What to tax? (value creation) – how to attribute profit in new digitalised business models driven 

by intangible assets, data and knowledge.  

These challenges need to be looked at together to find a meaningful solution for determining where 
economic  activities  are  carried  out  and  value  is  created  for  tax  purposes.  The  issue  of  "Where  to 
tax?" – how to establish taxing rights in a country where a business only has a digital presence and no 
physical presence – can be illustrated by the following theoretical example. 

Theoretical example of a business which provides a social network that relies on advertising revenues 
by delivering targeted marketing messages to its users in the EU:   

Users located in the EU have free access to a social network run by a business located outside of the 
EU. The business collects data on its users, for example information on their spending habits, tastes 
and  preferences.  Although  the  business  mainly  generates  income  from  selling  advertising  space  to 
other  businesses  to  deliver  targeted  marketing  messages  via  the  network  to  its  users  in  the  EU,  it 
may  not  have  a  taxable  presence  in  the  EU  under  the  current  international  tax  framework  and 
therefore the business is not subject to corporate tax in the EU.  

Theoretical example of a business that provides digital services to customers in the EU via an online 
platform:   

Customers located in the EU pay subscription fees to access digital services (e.g. music or video) via 
an online platform run by a business located outside of the EU. Although the revenue generated from 
the subscription fees comes from customers in the EU, the platform provider does not have a taxable 
presence in the EU under the current international tax framework and therefore the business is not 
subject to corporate tax in the EU.  

To  address  these  challenges,  it  is  crucial  to  create  and  sustain  international  momentum  on  this 
issue at political level, which has been quite weak up to now because of the multitude of actors and 
a lack of consensus in the international debate. It remains that the ideal approach would be to find 
multilateral,  international  solutions  to  taxing  the  digital  economy  given  the  global  nature  of  this 
challenge.  

The  Commission  considers  that  EU  Member  States  should  have  a coordinated  position  to  have  a 
greater  impact  on  the  work  at  global  level.  They  should  converge  and  promote  an  approach  that 
would lead the work towards an ambitious outcome. The outcome should stabilise the tax bases of 
the  individual  Member  States,  and  ensure  fair  competition  and  the  flourishing  of  companies 
operating within the Single Market. In its international discussions, the EU should ensure that profits 
generated in the EU are effectively taxed by the EU Member States and redistributed fairly. 

7 

 
 
 
 
 
An Important milestone will come early in 2018 when the OECD will present an interim report on 
the taxation of the digital economy to the G20.  It is essential that this report comes to appropriate 
and  realistic  conclusions  on  the  way  ahead  and  identifies  genuine  policy  options  to  tackle  the 
challenge.  

In parallel, the EU must examine all possible options so as to adopt new rules for taxing the digital 
economy within the Single Market. It should also focus on EU solutions if progress at international 
level proves too slow.  

Objectives 

A comprehensive and modern approach to the taxation of the digital economy is needed to meet the 
goal of fairer and more efficient taxation, and to support EU growth and competitiveness through the 
Digital Single Market. This approach should be driven by the following objectives: 

- 

Fairness – Ensuring that corporate profits are taxed where the value is created. It is necessary to 
maintain a  level  playing field and  a  system  that is  resilient against  abuse so  that  all  companies 
pay their fair share whether they are large or small, more or less digitalised, EU or non-EU based. 

-  Competitiveness  –  Creating  the  right  tax  environment  for  the  scaling-up  of  start-ups  and 
businesses to flourish in our Single Market. To improve the competitiveness of the EU, we need 
to  remove  existing  obstacles  and  avoid  creating  new  tax  barriers  to  the  emergence  of  new 
businesses that foster innovation and create jobs.  

- 

- 

Integrity  of  the  Single  Market  –  Converging  towards  a  common  solution  that  avoids  unilateral 
measures  that  would  destabilise  the  functioning  of  the  Single  Market.  Uncoordinated  national 
measures will lead to fragmentation of the Single  Market, further distortions and tax obstacles 
that will prevent companies from growing and investing in the Single Market.   

Sustainability  –  Ensuring  the  corporation  tax  system  is  future-proofed  and  sustainable  in  the 
long-term.  As  traditional  business  models  become  increasingly  digitalised,  Member  States'  tax 
bases  could  gradually  disappear  if  the  tax  rules  are  not  adapted  to  capture  new  digitalised 
business models. If not remedied this will lead to the tax burden being increased elsewhere.  

The way ahead 

EU citizens and governments are increasingly concerned by the perceived imbalances in the levels of 
taxation  of  the  new  digitalised  business  models.  Failure  to  agree  on  a  meaningful  solution  in 
adequate  time  will  exacerbate  the  pressure  to  act  at  national  level  and  will  undermine  the  Single 
Market.   

One solution is to embed the taxation of the digital economy in the general international corporate 
tax  framework.  Fundamental  reform  of  the  international  corporate  tax  framework  currently 
applicable  to  the  digital  economy  would  ensure  the  consistency  and  coherence  of  tax  rules 
worldwide, and ensure stability and certainty for businesses. The EU expects a high level of ambition 
as regards the interim report on the taxation of the digital economy that the OECD will present to the 
G20.  It  is  essential  that  the  report  comes  forward  with  meaningful  policy  options  to  address  the 
issues at stake.  

8 

 
In  particular,  new  international  rules  specific  to  the  challenges  raised  by  digital  economy  are 
needed to determine where the value of businesses is created and how it should be attributed for 
tax  purposes.  This  would  entail  reform  of  international  tax  rules  on  permanent  establishment, 
transfer pricing and profit attribution applicable to digital technologies. 

The permanent establishment rules are used to determine the threshold of activity that needs to be 
carried out in a country in order for a business to be taxable in that country, and are largely based on 
physical  presence.  However,  thanks  to  digital  technologies,  businesses  are  now  able  to  have  a 
significant  economic  presence  in  a  market  jurisdiction  without  necessarily  having  a  substantial 
physical presence. Alternative indicators for significant economic presence are therefore required in 
order to establish and protect taxing rights in relation to the new digitalised business models. 

Once  the  business  is  taxable  in  the  country,  the  profits  generated  by  this  business  still  need  to  be 
determined and allocated to this country. The transfer pricing rules are used to attribute the profit 
of multinational groups to the different countries based on an analysis of the functions, assets and 
risks  within  the  value  chain  of  the  group.  However,  these  rules  were  developed  for  traditional 
business models and economic environment. The digital economy relies heavily on intangible assets, 
which  are  becoming  more  and  more  the  value  drivers  within  multinational  groups  and  which  are 
difficult  to  value.  The  challenge  of  identifying  and  valuing  intangible  assets  as  well  as  determining 
their  contribution  to  value  creation  requires  alternative  methods  for  attributing  profit  that  better 
capture value creation in the new business models, which should therefore be considered alongside 
changes  to  the  permanent  establishment  rules.  Furthermore,  as  profits  can  be  shifted  across 
countries  through  misuse  of  permanent  establishment  and  transfer  pricing  rules,  anti-abuse  rules 
could be considered to enforce compliance and ensure that profits earned in the EU are taxed in the 
EU.  

At EU level, the Common Consolidated Corporate Tax Base proposal offers a basis to address these 
key challenges. The Commission continues to believe that the CCCTB provides an EU framework for 
revised  permanent  establishment  rules  and  for  allocating  the  profit  of  large  multinational  groups 
using  the  formula  apportionment  approach  based  on  assets,  labour  and  sales  that  should  better 
reflect  where  the  value  is  created.  There  is  scope  within  the  current  CCCTB  proposal  to  examine 
further enhancements to ensure that it effectively captures digital activities. Discussions are already 
underway on this in the Council under the Estonian Presidency and in the European Parliament. The 
Commission  stands  ready  to  work  with  Member  States  in  examining  these  options  within  the 
ongoing  CCCTB  negotiations,  to  find  an  ambitious  and  EU-law  compatible  approach  for  the  Single 
Market.   

Arriving at a meaningful solution to capture and allocate the value created in the digital economy 
across countries can take time.  This is further complicated by the multidimensional nature of this 
challenge, to the constantly changing nature of the digital economy, and the diversity of the business 
models and the complexity of ecosystems in which they create value. However, the longer it takes to 
find a solution, the bigger the losses in tax revenues will be. Therefore, unilateral initiatives in the EU 
and  internationally  will  continue  to  develop.  Since  2016,  countries  such  as  India  and  Israel  have 
already been testing alternative approaches to ensure effective taxation of the digital economy.  

9 

 
Alongside the work on this longer-term strategy,  there are also more immediate,  supplementary 
and short-term measures that should be considered to protect the direct and indirect tax bases of 
Member  States.  Different  ideas  have  been  presented  in  the  EU  and  internationally  to  capture  the 
digital  activity  in  an  alternative  way  to  the  international  corporate  tax  framework,  and  to  ensure 
equal treatment and a level playing field for all businesses. 

Some alternative options for shorter-term solutions 

  Equalisation tax on turnover of digitalised companies - A tax on all untaxed or insufficiently 
taxed income generated from all internet-based business activities, including business-to-
business and business-to-consumer, creditable against the corporate income tax or as a separate 
tax.  

  Withholding tax on digital transactions - A standalone gross-basis final withholding tax on 
certain payments made to non-resident providers of goods and services ordered online. 
Levy on revenues generated from the provision of digital services or advertising activity - A 
separate levy could be applied to all transactions concluded remotely with in-country customers 
where a non-resident entity has a significant economic presence.  

 

All short-term options have pros and cons, and further work is needed on the detailed approach to 
find a workable solution for the Single Market and the global economy as a whole. Questions about 
the compatibility of such approaches with the double-taxation treaties, State aid rules, fundamental 
freedoms,  and  international  commitments  under  the  free  trade  agreements  and  WTO  rules  would 
need  to  be examined.  Yet  something  has  to  be  done. The Commission  remains  convinced  that  the 
appropriate level of action is the EU. Only a coordinated EU approach will ensure that the solution is 
fit  for  the  Digital  Single  Market  and  can  deliver  on  our  objectives  of  fairness,  competitiveness  and 
sustainability.     

Conclusion  

This  Communication  calls  for  a  strong  and  ambitious  EU  position  on  taxing  the  digital  economy, 
which  should  feed  into  ongoing  international  work on  the issue. It also  aims  to  provide  a  basis  for 
further political discussions amongst Member States at the Tallinn Digital Summit of 29 September, 
so as to reach a common position in the international discussions.  

The  Commission  will  support  the  Estonian  Presidency  in  its  work  on  these  issues  with  a  view  to 
stabilise  by  the  end  of  the  year  Council  conclusions  setting  out  a  coordinated  EU  approach.  These 
conclusions would form the common basis that EU and its Member States would use to put forward 
proposals in the international discussions.  

The EU expects meaningful progress in the global agenda and should push for this to be reflected in   
the  OECD  report to  the  G20  Finance  Ministers  at  their  meeting in  April 2018.  The  Commission  will 
contribute to a successful conclusion of the on-going global discussions at the G20.  

In  the  absence  of  adequate  global  progress,  EU  solutions  should  be  advanced  within  the  Single 
Market  and  the  Commission  stands  ready  to  present  the  appropriate  legislative  proposals.  The 
Commission will continue to analyse the policy options and consult with relevant stakeholders and 

10 

 
 
 
industry representatives on this important and pressing issue ahead of a possible proposal by spring 
2018.  

11