European Commission proposes financial contribution for EU companies and permanent establishments

Following the publication of two New Own Resources (NOR) packages in 2021 and 2023, and complex negotiations among Member States, the European Commission released a new NOR proposal on 16 July 2025 (the ‘Proposal’). The Proposal builds on previous NOR packages, introducing targeted adjustments and clarifications to existing own resources, while reiterating two NORs already put forward in earlier proposals (i.e., ETS and CBAM). The novelty of the Proposal is the introduction of three additional resources, namely: (i) a contribution based on the amount of electric and electronical equipment non-collected (e-waste); (ii) a Tobacco Excise Duty Own Resource (TEDOR); and (iii) a Corporate Resource for Europe (CORE).

A Corporate Resource for Europe (CORE): Scope and Impact

The proposed CORE would apply to EU resident companies and EU permanent establishments (PE) of non-EU country entities with an annual net turnover above EUR 100 million.

CORE would be established as annual lump-sum based on the net turnover of companies and PEs in scope, with higher net turnovers resulting in progressively larger contributions per a ‘bracket system’. The CORE contribution will be calculated using standard corporate data and it would be applied at company or PE level, i.e., not at group level.

The annual contribution from an in-scope company / PE will be determined according to the following brackets:

Member States will be responsible for collecting the CORE on behalf of the Union and remitting the funds to the Commission.

Specific aspects of the CORE (and other types of own resources) will be included in implementing measures to be adopted by the Council. These implementing measures would establish rules detailing the specific obligations for companies under the CORE, as well as those necessary for the proper administration, collection, and enforcement of the contribution.

Next Steps and Entry into Force

The Proposal is based on Article 311(3) of the TFEU and, therefore, its adoption in the Council requires consultation with the European Parliament (non-binding) and unanimity from Member States. Additionally, the entry into force of the Proposal requires Member States’ national approval and notification to the Council in accordance with their respective constitutional requirements.

The aim of the Commission is to apply the new own resources embodied in the Proposal as of 1 January 2028. The Proposal however states that the CORE would start to apply as of 1 January of the first calendar year following the year in which the Proposal would enter into force. The CORE could therefore apply already as of 1 January 2027, if the Proposal enters into force in the course of 2026.

At this stage, it is uncertain whether unanimity from Member States can be achieved, however. Previous negotiations on the NOR packages proposed in 2021 and 2023 have shown that unanimity is challenging due to the divergent positions of Member States. The new long-term budget cycle will take effect in January 2028 and the EU needs own resources (to finance among others the green and digital transition, defence needs and repayment obligations of NextGenerationEU). It is therefore possible that this time the additional time pressure will push Member States to reach an agreement. Negotiations on the Proposal are expected to last well into 2026 and potentially into 2027. Furthermore, the CORE proposal has a few legal challenges (e.g., legal basis and impact of tax treaties).

We will keep you informed about new developments. Should you have any questions please contact your regular adviser at Loyens & Loeff or one of the contact persons mentioned below.