CFE’s Tax Top 5 – 2 February 2026

BRUSSELS | 2 FEBRUARY 2026

OECD Webinar on the Revised Manual on Effective Mutual Agreement Procedures

On 10 February 2026, the OECD will hold a technical webinar from 12:30–13:45 CET to present the 2026 edition of the Manual on Effective Mutual Agreement Procedures. The 2026 revised Manual updates and expands the original 2007 Manual, reflecting recent developments in international tax cooperation and dispute resolution. It aims to strengthen tax certainty by promoting more comprehensive practical guidance and best practices for the effective conduct of the mutual agreement procedure (MAP) under tax treaties, for use by both competent authorities and taxpayers. The updated Manual also includes practical guidance on MAP arbitration, which was not addressed in the original version.

During the webinar, senior OECD officials and tax practitioners will present the key elements of the revised Manual, including close to 60 best practices covering each stage of the MAP process, measures aimed at the proactive prevention of disputes, and guidance on the organisation of an efficient and effective competent authority function.

The session will offer government officials, business stakeholders and tax practitioners insights into the revised Manual as an end-to-end resource for navigating the MAP process and strengthening cross-border tax dispute resolution. Those interested to participate can register at this link.

EU Parliament Hearing on Single Market Tax Barriers & Cost of Non-Europe in Tax Harmonisation 

At its meeting on 27 January 2026, the European Parliament’s Subcommittee on Tax Matters (FISC) held a public hearing on “Tackling tax obstacles in the Single Market”, alongside a presentation of the European Parliamentary Research Service (EPRS) Cost of non-Europe report on EU tax policy harmonisation.

Speakers highlighted the scale of tax fragmentation across the EU, pointing to the very high number of national tax expenditures which contribute to duplicated compliance obligations. SMEs, representing around 95% of EU businesses, were estimated to lose more than one fifth of turnover to tax compliance, while transfer pricing disputes continue to increase amid divergent national definitions and thresholds.

The Commission indicated that a broad simplification package is planned for June, including a review of around 15 tax directives, the removal of unused reporting requirements and consideration of lighter compliance for groups within scope of Pillar Two, given the global 15% minimum tax. Possible repeal of overlapping rules, including ATAD, was also referenced.

The hearing discussed potential short-term improvements, such as simplified compliance pathways for SMEs, faster and more accessible tax rulings, and mandatory escalation mechanisms in joint audits to prevent lengthy disputes.

The study concluded that targeted EU-level coordination, rather than full harmonisation, could best reduce compliance costs, strengthen enforcement and limit arbitrage in areas including wealth taxation, cryptoassets, digitalisation of tax administration and tax compliance.

CFE Opinion Statement on the 2026 EU Rule of Law Reports

CFE Tax Advisers Europe has submitted an Opinion Statement in response to the European Commission’s public consultation on the 2026 EU Rule of Law Reports.

While supporting the legitimate objectives of effective tax enforcement, AML measures and administrative cooperation, the Statement highlights growing rule-of-law challenges linked to the steady expansion of tax administration and enforcement powers across the EU. CFE draws particular attention to issues relating to access to taxpayer data, mandatory disclosures and increasingly extensive cross-border information exchange.

Referring to recent case law of the European Court of Human Rights and the Court of Justice of the EU, CFE underlines that tax enforcement is fully subject to fundamental rights guarantees and cannot be exempt from requirements of legal certainty, proportionality and effective judicial protection. The Opinion stresses the importance of safeguards functioning not only in law but also in practice, and of ensuring access to effective judicial review, including interim relief, in highly technical and data-driven tax domains.

CFE calls on the Commission to use the Rule of Law cycle to assess the practical effectiveness of safeguards and remedies in tax and related administrative areas, including the protection of professional secrecy.

OECD Global Forum on VAT Focuses on Future-Ready VAT Systems

The OECD held its sixth Global Forum on VAT in Paris last week from 26 to 28 January 2026. Discussions focused on how rapid digital transformation is reshaping business models and cross-border trade, placing pressure on traditional VAT frameworks. Participants examined the implications for VAT policy and administration, including challenges linked to revenue collection, compliance and enforcement, as well as the need for systems that can accommodate new forms of digital commerce while maintaining neutrality and efficiency.

The forum also provided a platform for jurisdictions to exchange practical experience and best practices, including approaches to modernising VAT administration through the use of digital tools and data-driven compliance measures. These exchanges reflected broader international efforts to strengthen VAT systems as a stable source of revenue while limiting administrative burdens for both tax authorities and businesses.

The meeting coincided with the tenth anniversary of the OECD International VAT/GST Guidelines, highlighting their continued relevance as a reference point for the international VAT framework. The discussions underscored the importance of sustained engagement between governments and business stakeholders as VAT systems continue to evolve in response to digitalisation and globalisation.

January Infringement Package: Commission Pursues Enforcement on Tax Transparency & Customs Obligations

In its January infringement package, the European Commission opened several tax-related infringement procedures concerning the transposition and implementation of EU administrative cooperation and customs legislation.

Letters of formal notice were sent to Belgium, Bulgaria, Czechia, Estonia, Greece, Spain, Cyprus, Luxembourg, Malta, the Netherlands, Poland and Portugal for failing to fully transpose Directive (EU) 2023/2226 (DAC8), which amends the Directive on administrative cooperation in the field of taxation to introduce tax transparency and information exchange rules for crypto-assets and to strengthen reporting on financial accounts. The Commission recalled that the directive aims to address gaps in tax transparency linked to crypto-asset investments and to reinforce the exchange of information between tax authorities.

The Commission also sent letters of formal notice to Belgium, Bulgaria, Czechia, Greece, Cyprus, Malta, the Netherlands, Portugal, Romania and Sweden for incomplete transposition of Directive (EU) 2025/872, which further amends the administrative cooperation framework in taxation by introducing new information exchange requirements. The Member States concerned have been given two months to complete their transposition and notify the Commission, after which the Commission may decide to proceed to the reasoned opinion stage.

The January infringement package also includes reasoned opinions addressed to Denmark and Slovakia for failing to comply with their obligations under the Union Customs Code to transmit complete and standardised customs data via the SURV3 system, which the Commission considers essential for the uniform application of EU customs law and effective trade monitoring. In addition, a reasoned opinion was issued to Belgium for failing to fully implement the Temporary Storage system for air transport under the Union Customs Code, a core component of the EU’s digital customs framework that should have been operational by the end of 2023.

The selection of the remitted material has been prepared by:
Dr. Aleksandar Ivanovski & Brodie McIntosh