On May 18^th, 2021, the European Commission adopted a communication on business taxation for the 21^st century to develop a uniform, efficient and fair system of business taxation in the EU, encourage Europe’s recovery from the COVID-19 pandemic, and secure public revenues on a long-term basis to create and support a stable business environment required for sustainable growth. The communication proposes five action points to be implemented in the next two years to ensure fair and efficient taxation and enable productive investment and entrepreneurship. Under the heading “Business in Europe: Framework for Income Taxation”, or “BEFIT” for short, Action 5 proposes to develop a single corporate tax rulebook by 2023 providing for a fairer and less complicated allocation of taxation rights between the EU member states fit for the 21^st century. BEFIT shall replace the pending proposal for a common consolidated corporate tax base (CCCTB), which was withdrawn by the Commission. The Commission’s communication is part of a wider EU tax reform agenda under consideration of G20 and OECD’s preparatory work on Pillar I and Pillar II following the proposals adopted by 132 states of the OECD’s Inclus...