INTERNATIONAL TAX PLAZA - Initial phase of a group’s international activity

Details: Published: 23 February 2022

An MNE group shall be considered to be in the initial phase of its international activity if:

(a) it has constituent entities in no more than six jurisdictions; and

(b) the sum of the net book value of the tangible assets of all the constituent entities of the MNE group other than the constituent entities located in the reference jurisdiction does not exceed EUR 50 million.

For the purpose of point (b), reference jurisdiction means the jurisdiction in which the constituent entities of the MNE group have the highest sum of the net book value of tangible assets in the fiscal year in which the MNE group falls within the scope of this Directive for the first time.

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