The European Commission is considering restructuring its Corporate Resource for Europe (CORE) proposal into a flat levy for companies with over €100 million in annual EU revenue. This strategy aims to generate tax revenue from U.S. tech giants while avoiding potential retaliatory tariffs threatened by the U.S. government.
This regulatory shift represents a tactical pivot to treat digital platforms as general large-scale enterprises rather than a unique tax class. For streaming giants like Amazon and Meta, this flat-fee approach could become a predictable cost of doing business compared to the volatile 100% retaliatory tariffs threatened by the U.S. government. By including European banks and manufacturers in the scope, the Commission creates a legal shield against claims of anti-American discrimination. The broader streaming ecosystem must now account for these fixed regional operating costs as part of their European margin calculations. Watch for whether individual member states like France and Italy retire their national digital taxes in favor of this unified EU-wide contribution.
The European Commission's Corporate Resource for Europe proposal has been one of five new "own resources" designed to raise approximately €60 billion annually from 2028 onward as part of the EU's multi-year budget framework. Dealroom reported that CORE was first proposed in July 2025 within the Commission's roughly €2 trillion budget plan for 2028-2034, and that a majority of EU member states currently oppose the mechanism in its original form. The expansion under discussion would raise the bracket amounts that currently cap contributions at €750,000 per entity while maintaining the sector-neutral framing that applies equally to manufacturers, banks, and technology firms. An EU official told the Financial Times that some capitals oppose a pure digital tax to avoid upsetting the Americans, while many more oppose CORE itself, making expansion to all large companies the political compromise.
The tariff threat driving this design is specific and recent. President Donald Trump threatened in June 2025 to impose a 100% tariff on all goods from any country that imposes a digital services tax on American companies, a penalty he said would override existing trade agreements. France, Italy, Spain, and Austria already operate national digital levies and face U.S. Section 301 investigations that could lead to retaliatory tariffs. The Commission's bet is that CORE's sector-neutral legal architecture, which does not mention digital companies or reference advertising revenue, will be sufficient for the Trump administration to treat it differently than it has treated France's 3% revenue levy or the UK's 2% digital services tax. However, the U.S. Trade Representative's office has historically evaluated such measures by their effective incidence rather than their stated sector neutrality.
The 2021 OECD global tax deal, which was intended to provide a multilateral framework for taxing multinationals, has effectively stalled following Trump's 2024 re-election. TechTimes reported that an EU official described the OECD agreement as "dead" in practice, leaving the Commission to pursue unilateral mechanisms like CORE. The EU had previously shelved its own digital levy to make room for that global deal, and officials now say a digital-only tax is unlikely to win sufficient support among the 27 member states given fears of U.S. retaliation. Any change to CORE requires unanimous ratification across all member states, a threshold that remains the proposal's most significant political obstacle.
The European Commission is proposing a sector-neutral corporate levy for companies generating over €100 million in annual EU revenue. By treating tech giants like Apple and Meta as general large-scale enterprises, Brussels aims to secure tax revenue while avoiding the 100% retaliatory tariffs threatened by the U.S. government.
The proposed CORE framework would apply a fixed annual payment to any company that generates over €100 million in annual regional revenue within the European Union.
The EU is shifting to a sector-neutral levy to avoid U.S. trade retaliation, specifically the 100% tariffs threatened by Donald Trump against nations that implement discriminatory digital services taxes.
No, the proposed CORE framework is sector-neutral. It is designed to apply equally to large-scale enterprises, including European banks, manufacturers, and technology firms.
The 2021 OECD global tax deal is considered effectively dead following Donald Trump's 2024 re-election, leading the European Commission to pursue unilateral mechanisms like CORE.
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