The European Commission (EC) has sent notice letters to nine Member States warning them that they were 'not in compliance with EU law' over the 15% minimum corporation tax mandated by the G20/OECD Inclusive Framework, Directive (EU) 2022/2523, known as the Pillar 2 directive. 

The minimum rate of tax for multinational companies active in EU Member States was introduced on 1 January 2024 .

The EC said in a statement; "This important Directive brings greater fairness and stability to the tax landscape in the EU and globally by limiting the race to the bottom in corporate tax rates and lowering the incentive for businesses to shift profits to low-tax jurisdictions."

Nine Member States – Estonia, Greece, Spain, Cyprus, Latvia, Lithuania, Malta, Poland and Portugal – had not communicated national measures transposing the Directive by the deadline of 31 December 2023.

Some of the countries, namely Cyprus, Estonia, Latvia, Lithuania and Malta have has said that they will delay Pillar Two implementation, or at least do it in stages. While Spain has said its draft implementation will mostly have a retrospective effect to 1 January 2024.