COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS An adjusted package for the next generation of own resources
Date: 2023-06-20
Institutions: Directorate-General for Budget, European Commission
Subjects: EU Emissions Trading Scheme, EU budget, carbon neutrality, corporation tax, economic recovery, multinational enterprise, own resources

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 20.6.2023  COM(2023) 330 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS An adjusted package for the next generation of own resources  
 
 
1.  NEW OWN RESOURCES: TAKING STOCK OF PROGRESS 

for 

the 

In  2020,  the  European  Parliament,  the  Council  and  the  Commission  agreed  on  a 
taking  account  of 
introduction  of  new  own  resources 
roadmap 
NextGenerationEU1. According to this agreement, “the expenditure from the Union budget 
related to the repayment of the European Union  Recovery  Instrument should not lead to an 
undue  reduction  in  programme  expenditure  or  investment  instruments  under  the  MFF.  It  is 
also  desirable  to  mitigate  the  increases  in  the  GNI-based  own  resource  for  the  Member 
States”. Hence “the Institutions will work towards introducing sufficient new own resources 
with a view to covering an amount corresponding to the expected expenditure related to the 
repayment.  In  accordance  with  the  principle  of  universality,  this  would  not  imply  an 
earmarking  or  assignment  of  any  particular  own  resource  to  cover  a  specific  type  of 
expenditure”. 

In December 2021, the Commission proposed three new sources of revenues for the EU 
budget2 with contributions from the Emissions Trading System (ETS), from the EU Carbon 
Border  Adjustment  Mechanism  (CBAM)  and  from  a  share  of  the  residual  profits  of  the 
largest  multinational  enterprises  that  would  be  reallocated  to  the  EU  under  the  OECD/G20 
Pillar 1 agreement. This basket of own resources was consistent with the proposed sectorial 
legislation  on  both  the  revised  ETS  Directive  and  on  the  Carbon  Border  Adjustment 
Mechanism proposed earlier in the same year.  

The  Commission  committed  to  come  forward  with  further  proposals  for  new  own 
resources by the end of 2023. The legislative discussions on the proposal made in December 
2021 have made limited progress. Today, the Commission proposes to adjust the first basket 
of new own resources taking into account the agreement on the Fit For 55 and developments 
since then, and proposes to add a new statistical based own resource . With this proposal, the 
Commission  considers  that  Member  States  have  all  the  necessary  elements  to  progress  on 
their  negotiations,  in  the  framework  of  the  agreed  roadmap.  The  Commission  calls  on  the 
Council to accelerate these negotiations. 

2.  FIT FOR 55 AND NEW OWN RESOURCES – AN ADJUSTED PACKAGE  

In December 2022, the EU agreed on a wide range  of proposals, which are part of the 
Fit  for  55  package,  with  the  objective  of  reaching  the  EU’s  2030  climate  target  of 
reducing greenhouse gas emissions by at least 55% compared to 1990 levels and climate 
neutrality  by  2050.  With  the  agreement,  the  EU  increased  –  first  –  the  ambition  of  the 
existing ETS. Second, it extended the scope of the ETS to maritime shipping emissions and 
phases  out  free  allowances  for  the  aviation  sector.  Third,  the  EU  set  up  a  new  emissions 
trading system for buildings, road transport and additional sectors. Fourth, a Social Climate 
Fund will be set up as of January 2026 to help Member States to address the impacts of the 

1  

Interinstitutional Agreement between the European Parliament, the Council of the European Union and the European 
Commission on budgetary discipline, on cooperation in budgetary matters and on sound financial management, as well 
as on new own resources, including a roadmap towards the introduction of new own resources (OJ L 433I , 22.12.2020, 
p. 28–46).  

2   Commission  proposal  of  22  December  2021  amending  Decision  (EU,  Euratom)  2020/2053  on  the  system  of  own 

resources of the European Union (COM/2021/570 final). 

1 

 
 
                                                           
new  emissions  trading  system  on  vulnerable  households,  transport  users  and  micro-
enterprises. Finally, a new Carbon Border Adjustment Mechanism will start in its transitional 
phase as of October 2023. Once the definitive system enters into force as of January 2026, it 
will reinforce climate ambitions of the EU and prevent carbon leakage.  

The basket of new own resources needs to be adjusted to reflect the Fit for 55 agreement 
and the changes agreed by the co-legislators. In particular, the Social Climate Fund will, as 
of  2026,  initially  be  financed  with  external  assigned  revenues  and  not,  as  proposed  by  the 
Commission in its December 2021 proposal, by general revenue under the Union budget. The 
Commission  proposes  to  postpone  the  introduction  of  the  own  resource  from  the  new 
emissions  trading  system  –  which  will  be  established  in  2027  –  to  2028.  For  the  existing 
emissions trading system the own resource can be introduced already. The Commission also 
proposes to reflect other aspects of the agreement in the proposed own resources legislation, 
such as the possibility to cancel allowances in case of national carbon taxes.  

Since  July  2021,  the  carbon  price  has  significantly  increased.  When  the  Commission 
presented the Fit for 55 legislative proposals, the carbon price assumption per tonne of CO2 
was  EUR  55  for  the  period  2026-2030  (in  2020  prices)3.  In  2022  the  carbon  price  in  the 
existing  ETS  has  increased  to  EUR  80.  Member  States’  annual  revenue  from  auctioning 
allowances  have  doubled  from  some  EUR  15  billion  in  2020  to  an  unprecedented  level  of 
almost EUR 30 billion in 2022. The Commission proposes a somewhat higher call rate for the 
ETS-based own resource: 30% from all revenues generated by EU emissions trading would 
accrue to the EU budget. With such a call rate, the amounts retained by Member States will 
still  be  higher  than  expected  when  proposing  the  Fit  For  55  legislation.  The  total  revenues 
generated  by  the  ETS  own  resource  would  reach  around  19  billion  per  year  from  2028 
onwards.  On  average,  EUR  46  billion  per  year  would  accrue  to  Member  States.4  The 
Commission  proposes  to  maintain  the  solidarity  adjustment  mechanism.  This  mechanism 
aims to ensure a fair contribution from all Member States, avoiding that some Member States 
contribute disproportionally to the EU budget in comparison to the size of their economy.  

As regards the own resource based on the Carbon Border Adjustment Mechanism, the 
Commission considers that the proposed call rate remains adequate. The Carbon Border 
Adjustment Mechanism is expected to generate around 1.5 billion for the EU budget as from 
2028.  Following  the  agreement  on  a  new  governance  model,  which  has  increased  the 
centralisation of the number of tasks at EU level, the Commission accordingly proposes some 
technical adjustments to the control framework. 

3.  A BASKET COMPLEMENTED WITH A TEMPORARY STATISTICAL BASED  OWN RESOURCE 

ON COMPANY PROFITS  

The implementation of the OECD/G20 Pillar 1 agreement remains an essential priority 
in the area of corporate taxation for the EU and its Member States. In December 2021, 

3 

See the Impact Assesment Report accompanying the Directive of the European Parliament and of the Council amending 
Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union, Decision 
(EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas 
emission trading scheme and Regulation (EU) 2015/75. SWD/2021/601 final. 

4   Based on a carbon price of EUR 80 for the existing ETS and CBAM. For the new ETS the assumed carbon price is 

derived from the 2021 impact assessment. 

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the  Commission  proposed  an  own  resource  based  on  a  share  of  residual  profits  from 
multinationals  that  will  be  re-allocated  to  EU  Member  States  under  the  OECD/G20 
agreement  on  so-called  ‘Pillar  One’.  This  agreement  addresses  the  tax  challenges  arising 
from  the  digitalisation  of  the  economy  and  will  reform  significantly  the  international 
corporate  tax  system.  Substantive  progress  has  been  made  following  the  October  2021 
agreement  and  the  Commmision  will  continue  to  promote  such  efforts.  However,  the 
multilateral convention has not  yet been signed and ratified, which means that it cannot  yet 
enter into force.  

As  announced  in  the  Commission  Work  Programme5,  the  Commission  intends  to 
propose its Business in Europe: Framework for Income Taxation (BEFIT) in  the third 
quarter  of  2023.  This  initiative  will  improve  the  functioning  of  the  Single  Market  by 
simplifying  corporate  tax  rules  and  tax  compliance,  and  levelling  the  playing  field  for 
businesses. BEFIT aims at tackling the complexity and double taxation, and at reducing tax 
compliance  costs  that  businesses,  chiefly  those  with  cross-border  activity,  currently  face  in 
the  Single  Market.  It  will  contribute  to  making  the  EU  more  attractive  to  cross-border 
investment  and  support  growth.  BEFIT  will  be  mandatory  for  large  groups  with  global 
combined  annual  revenues  of  EUR  750  million  or  more.  The  discussions  in  Council  are 
expected to start in the fourth quarter of 2023.  

Until  the  possible  establishment  of  an  own  resource  based  on  an  underlying  tax,  the 
Commission  is  proposing  a  statistical  own  resource.  This  own  resource  is  not  a  tax  on 
companies,  nor  does  it  increase  companies’  compliance  costs:  it  would  be  a  national 
contribution  calculated  on the basis of statistics  from national  accounts under the European 
system of accounts (ESA). It would help to balance the basket of own resources and further 
diversify the revenue sources for the EU budget. 

The  statistical  base  on  which  to  calculate  the  own  resource  contribution  would  be 
defined using a harmonised indicator that roughly approximates company profits: gross 
operating surplus. This notional EU company profit base would be calculated using sectoral 
national  accounts  for  financial  and  non-financial  corporations  according  to  the  European 
system of accounts 2010, which has the advantage of harmonised accounting across Member 
States.  It will be calculated by multiplying a call rate on  the gross operating surplus for the 
sectors  of  financial  and  non-financial  corporations.  Expected  revenues  would  be  around  16 
billion per year on average.  

4.  AN ADJUSTED PACKAGE TO ACCELERATE NEGOTIATIONS 

With this adjusted proposal expected to deliver annual revenues of up to EUR 36 billion 
on average over  the 2028-2030 period6, the Commission gives priority to a  package of 
new  own  resources  that  can  be  negotiated  immediately,  and  calls  the  Council  to 
accelerate the negotiations. With the proposal for a temporary statistical based own resource 
on company profits, Member States in Council now have all elements on the table to proceed 
with negotiatiations, towards a quick agreement.  

5 Commission Work Programme 2023. A Union standing firm and united. COM(2022)548. 

6 2018 prices, excluding revenues from a reallocated profits based own resource related to OECD Pillar 1.  

3