On 25 June 2026, the European Commission published a proposal to replace the lists of eligible companies in Annex I of three EU tax directives with a single, updated list covering all 27 EU Member States, and to delete the United Kingdom from Part B of Annex I to Directive 2009/133/EC. The proposal aims to simplify the Union framework on direct taxation and support growth and competitiveness.
The proposal amends Directives 2003/49/EC (interest and royalty payments), 2009/133/EC (mergers, divisions, transfers of assets and exchanges of shares), and 2011/96/EU (parent-subsidiary). The new Annex I for Directive 2003/49/EC lists specific legal forms for each Member State, including Belgian 'société anonyme'/'naamloze vennootschap', German 'Aktiengesellschaft', French 'société anonyme', Italian 'società per azioni', and others. Annex II replaces Part A of Annex I to Directive 2009/133/EC with the same list and deletes the last indent in Part B, which referred to UK corporation tax. Annex III replaces Part A of Annex I to Directive 2011/96/EU with the same list.
The standardisation reduces administrative burden for companies operating across the EU by providing a uniform reference for eligible entities. The removal of the UK reflects its exit from the EU and ensures that UK companies no longer benefit from the tax advantages under Directive 2009/133/EC. The proposal is expected to be discussed by the Council in the coming months, with the European Parliament to be consulted.