CFE’s Tax Top 5 – 8 September 2025

The European Commission has fined Google €2.95 billion Euro for abusing its dominant position in the online advertising technology market, marking one of the largest antitrust penalties ever imposed in the EU. The Commission found that Google systematically favoured its own ad exchange, AdX, through its ad server and buying tools, in breach of Article 102 TFEU. By doing so, Google gave AdX an unfair advantage over rival platforms, distorting competition and harming publishers, advertisers and ultimately consumers.

The Commission has ordered Google to end these self-preferencing practices and to implement measures to address inherent conflicts of interest across the adtech supply chain. Google has 60 days to propose remedies or face further action, with the Commission noting that only divestment may adequately resolve the competition concerns. Executive Vice-President Teresa Ribera said of the antitrust penalty: “Google must now come forward with a serious remedy to address its conflicts of interest, and if it fails to do so, we will not hesitate to impose strong remedies… Digital markets exist to serve people and must be grounded in trust and fairness.”

The fine has sparked a backlash from former US President Donald Trump, who described it as “very unfair” and threatened retaliatory tariffs, claiming it punishes American companies and undermines fair trade. The Commission, however, has insisted that competition enforcement operates independently of political considerations and applies equally to all companies active in the European market. The case coincides with similar proceedings in the United States, where a judge has already found Google in breach of competition law over comparable adtech practices. A remedies trial is scheduled to begin later this month. 

OECD Revises BEPS Action 5 Transparency Framework & XML Schema

The OECD has published a revised version of the BEPS Action 5 minimum standard on the spontaneous exchange of information on tax rulings, referred to as the transparency framework. The revisions follow a comprehensive effectiveness review carried out by the OECD/G20 Inclusive Framework on BEPS, aimed at improving the functioning of the standard in light of almost a decade of practical experience among member jurisdictions. Since the launch of the BEPS Project, more than 58,000 exchanges of information have taken place, covering over 26,000 tax rulings identified by participating jurisdictions. The revised framework includes updated terms of reference and a new assessment methodology, which will form the basis of peer review processes from 2026 onwards.

In parallel, the OECD has released a revised version of the Exchange on Tax Rulings XML Schema and the associated User Guide, which have been updated to reflect the findings of the review. The revised schema will apply to spontaneous exchanges taking place from 1 January 2027. The changes are intended to enhance the overall effectiveness, consistency and reliability of tax ruling exchanges under the BEPS minimum standards.

Final Registration Reminder: 2025 CFE Tax Symposium in Ghent on 18 September 2025 

The 2025 CFE Tax Symposium will take place on Thursday, 18 September 2025, at the historic Oude Vismijn in Ghent, Belgium. Hosted in partnership with the Institute for Tax Advisors and Accountants Belgium, this year’s symposium, “Taxation in Transition: Compliance, Rights & Innovation in a High-Data World”, will convene policymakers, academics, and leading practitioners to examine the practical impact of the latest EU and international tax policy developments. 

The morning’s first panel will examine the EU & international tax policy landscape, moderated by CFE Director Aleksandar Ivanovski. Speakers will include Benjamin Angel (European Commission), Felicie Bonnet (OECD), Jorge Ferreras Guiterrez (Ministry of Finance, Spain), Helen Pahapill (Ministry of Finance, Estonia), and Prof. Dr. Georg Kofler (WU Vienna). They will discuss OECD Pillar Two implementation, EU simplification efforts, and broader cross-border trends.

After a networking lunch, the focus will turn to DAC and Taxpayers’ Rights, in a panel moderated by Eduardo Gracia Espinar (Ashurst EMEA, Spain) with panelists Reinhard Biebel (European Commission), Dr. Viktoria Wöhrer (WU Vienna, invited), and Philippe Vanclooster (ITAA), examining DAC recast, proportionality of sanctions, taxpayer rights, and the use of pre-populated tax returns.

The final panel on the interplay of AI, tax technology & indirect tax, chaired by Jeremy Woolf (Pump Court, UK), will bring together Jane Mellor (CIOT, UK), Nicholas Devillers (BDO, Luxembourg), and Petra Pospíšilová (Czech Chamber of Tax Advisers) to discuss AI-enabled compliance tools, real-time VAT reporting (MOSS, IOSS, VIDA), secure IT architecture, and ethical data use. 

Secure your place at the conference and register now!  More information and registration is available here.

OECD’s 2025 Tax Policy Reforms Report Tracks Trends Across 86 Jurisdictions 

The OECD will publish the 10th edition of its annual Tax Policy Reforms report on Thursday 11 September 2025. The 2025 edition reviews tax policy developments across 86 jurisdictions, including all OECD countries, and highlights how governments have used tax policy to address current economic complexities.

The report provides a comparative analysis of reforms announced or implemented in 2024, with a focus on trends in personal and corporate income taxes, VAT/GST, and green taxation. It also examines how countries are using tax policy to respond to consecutive global crises, high inflation, and long-term structural challenges such as ageing populations and digitalisation.

EU Commission Finalises Multiannual Financial Framework 2028-2034 with Boost to Tax & Customs Programme

EU Commission Finalises Multiannual Financial Framework 2028-2034 With Boost to Tax & Customs Programme 

The European Commission has finalised its proposal for the EU’s Multiannual Financial Framework (MFF) covering the period 2028–2034, setting out a €2 trillion budget. The final legislative package includes seven new sectoral programmes, completing the framework for the next long-term budget cycle.

A significant component is the proposed €6.2 billion Single Market and Customs Programme, which merges previously separate initiatives in the areas of market regulation, customs, taxation and anti-fraud into a unified financial instrument. The programme is intended to support the deeper integration of the EU Single Market by removing internal barriers, streamlining rules, and enhancing cooperation between national authorities. In addition to strengthening consumer protection and harmonising standards across Member States, it will also fund the collection and dissemination of official EU statistics, which underpin evidence-based policymaking.

The tax strand—Fiscalis—will focus on further modernising cross-border digital infrastructure and supporting cooperation projects to combat tax fraud and evasion. Overall, the programme is expected to reinforce the EU’s economic resilience, reduce administrative burdens, and promote regulatory consistency across Member States.

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