The Tax Omnibus Directive: A Trojan Horse for EU tax sovereignty

On 24 June 2026, the EU Commission adopted a draft directive proposing amendments to six existing EU directives (the "Tax Omnibus Directive"). The stated purpose of the amendments is to simplify the EU's framework for direct taxation and support the growth and competitiveness of the EU. However, in its current form, the directive more closely resembles a Trojan horse that would further erode the tax sovereignty of EU Member States.

The Tax Omnibus Directive proposes amendments to the following six EU Directives:

  1. Interest and Royalty Directive (Council Directive 2003/46/EC)
  2. Parent-Subsidiary Directive (Council Directive 2011/96/EU)
  3. Tax Merger Directive (Council Directive 2009/133/EC)
  4. Anti-Tax Avoidance Directive (Council Directive (EU) 2016/1164)
  5. Dispute Resolution Mechanism (Council Directive (EU) 2017/1852)
  6. Directive on Faster and Safer Relief of Excess Withholding Taxes – FASTER (Council Directive EU 2025/50)

In this ATOZ Alert, Tax Partner, Oliver R. Hoor, and Chief Knowledge Officer, Marie Bentley, detail the most significant changes set out in the Tax Omnibus Directive and analyse its implications.