EU Rejects US Firms in Tax Simplification
A European Commission tax director says US multinationals should not be included in proposed simplifications to the global minimum tax framework.
Updated on Nov. 3, 2026 in International Trade
Benjamin Angel, director for direct taxation at the European Commission, rejected including US companies in proposals to simplify the Pillar Two global minimum tax of 15%. His stance follows a January OECD-brokered agreement that carved US multinationals out of two key Pillar Two rules.
Why it matters
The position signals continued friction between the EU and the US over how the global minimum tax applies to American multinationals. It shapes how companies with operations in Europe will be taxed under the 15% minimum framework.
The global minimum tax rate under Pillar Two is 15%, the figure against which the proposed simplifications are being assessed. The stub does not indicate how many companies or what revenue volume would be affected by the carve-out or the proposed changes.
The players
Benjamin Angel
Benjamin Angel is director for direct taxation at the European Commission, the EU body responsible for proposing tax policy across member states.
Organisation for Economic Co-operation and Development (OECD)
The OECD is an intergovernmental body based in Paris that brokers international tax standards, including the Pillar Two global minimum tax framework.
The details
Angel stated the Commission's position at a European tax event, saying US multinationals should not be included in the simplification proposals. The January OECD-brokered agreement had already excluded US companies from two key Pillar Two rules, and the new stance concerns whether that carve-out extends to the wider simplification effort.
Timeline
January 2026: OECD-brokered agreement carves US multinationals out of two key Pillar Two rules.
November 3, 2026: Angel rejects including US companies in the simplification proposals.
Market Dynamics
The 15% minimum tax under the OECD Pillar Two framework is the central reference point for the dispute. The EU's refusal to extend the January US carve-out to its simplification proposals places the Commission at odds with the arrangement the OECD brokered for American multinationals.
For multinational companies with operations in Europe, the 15% minimum tax under Pillar Two sets a floor on effective tax rates. Whether US firms receive the same carve-outs in the simplification proposals will determine how much tax exposure those companies face in EU markets.
The takeaway
Companies with cross-border operations should track whether carve-outs granted under the January OECD agreement survive the EU's simplification process. The 15% floor remains the baseline for planning, regardless of which exemptions ultimately apply.
Further reading
For broader context on cross-border tax disputes, explore International Trade coverage.
