Letter

Mr. Jürgen Ligi

Minister of Finance, Republic of Estonia

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111

EUROPEAN COMMISSION

Wopke Hoekstra

Member of the Commission

Brussels, 30 January 2026

Dear Minister Ligi,

Thank you for your letter sharing with us Estonia’s concerns regarding EU Directive

2022/2523 (Pillar 2 Directive) and Estonia’s overall perspective on international tax

discussions on which my services and your administration were in close contact throughout

December 2025.

At this stage, we can all welcome that an agreement on the ‘Side-by-Side package’ has

since been reached at the OECD Inclusive Framework and published on 5 January 2026.

This important milestone includes a commitment to undertake a stocktake by 2029 to

ensure that any substantial risks are addressed to preserve the policy objectives of Pillar 2.

We agree with you that such stocktake will provide an important opportunity to assess the

impact of the Pillar 2 and facilitate the ongoing monitoring of the rules’ implementation at

the global level. There seems to be general consensus about this among the jurisdictions

that have agreed to the Side-by-Side package at the OECD and I am grateful for Estonia’s

constructive line in securing this agreement.

In addition, in its statement at the ECOFIN Council on 12 December 2025, the Commission

also committed to assess the impact of the Side-by-Side package for the European Union

specifically, to be completed by the same deadline or earlier if ever the directive is

amended. This assessment will also include an examination of the use of Article 50 of the

Pillar 2 Directive and the possibility for an extension of the delayed implementation of the

income inclusion rule (IIR) and undertaxed payments rule (UTPR) by Estonia and the other

Member States concerned.

The Commission remains committed to simplifying the Pillar 2 rules. We are eager to

engage further and welcome continued collaboration to ensure that the EU’s

competitiveness is safeguarded and enhanced and that our objectives of ensuring a

minimum level of taxation on a broad and global scale are sustained.

Your sincerely,

Wopke HOEKSTRA

Electronically signed on 02/02/2026 16:43 (UTC+01) in accordance with Article 11 of Commission Decision (EU) 2021/2121