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This page compares three ideas that are shaping the debate on an EU-wide company regime:
Regime 0 (Bruegel): a targeted optional regime for innovative, high-growth startups.
EU–INC: a community proposal for a new pan-European company structure + registry + EU-wide stock options.
“28th regime” (European Commission): the Commission’s upcoming initiative (details still evolving until the draft law is published).
CEPS: Centre for European Policy Studies is a leading think tank and forum for debate on EU affairs
ETAF: The European Tax Adviser Federation (ETAF) is a European umbrella organisation for 220 000 tax professionals. Its main role and mission are to represent the regulated tax profession at European level in liaising closely with European policy makers.
Last updated: 13.04.2026
|
Dimension |
EU Inc. “the 28th regime” |
|
Regime 0 (Bruegel) |
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|---|---|---|---|---|---|
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Harmonisation scope (corporate / labour / tax / insolvency) |
Corporate law: harmonised (Regulation). Labour: national. Tax: national, except EU-ESO deferral. Insolvency: digital procedures included. |
Pan-EU company structure with central registry; keeps local taxes & employment, aims to remove cross-border friction |
Corporate regime focused on scale barriers; explicitly avoids harmonising general labour & tax |
||
|
Entry criteria (open vs selected) |
Non-listed innovative LLCs. Broader than Regime 0, not fully open. Innovation criteria to be defined. |
Generally framed as broadly usable for founders/innovative firms; details in proposal |
Selected / gated: innovation + credible growth plans; intended for startups (not incumbents) |
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|
Registry model (Hub0 vs national) |
EU digital interface → national registers initially → EU central register later. Branches via BRIS, once-only filing. |
EU-level central registry + dashboard |
EU-level one-stop digital registry concept (“Hub0”) |
||
|
ESOP / equity taxation principle |
EU-ESO (Arts. 71–87): tax deferred to sale only. Rate set by Member State. FISC hearing confirmed narrow scope: equity treatment + admin simplification, not broad tax harmonisation. |
Strong emphasis on EU-wide stock options (EU-ESOP concept) |
Strong push for tax at sale for founders/key equity holders (with holding period concept) |
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|
Dispute resolution / courts |
Not addressed. National courts apply. No EU-level fast-track (unlike Regime 0). |
Proposal discusses legal architecture; specifics depend on final text |
Alternative dispute resolution first; specialised/fast-track structure described |
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|
Procurement / subsidy non-discrimination |
Not explicitly addressed. No specific procurement/subsidy non-discrimination clause yet. May emerge in negotiations. |
Generally pro “operate anywhere” principle; details in proposal |
Explicit: Regime 0 firms should be treated like national firms; no discrimination |
|
Dimension |
Bruegel (Regime 0) |
|
ETAF |
|
|---|---|---|---|---|
|
Approach |
Targeted regime for innovative ventures; digital hub ("Hub0"); regulation preferred over directive |
Modular tax layer added on top of corporate-law base; interoperability-first |
Simplification yes; warns against parallel complexity; soft-law path if unanimity blocks |
|
|
Key tax element |
Equity/stock-option taxation at sale (not at grant/issuance), with holding period |
Neutrality (no penalty for opting in), cross-border loss relief, mobility rules, WHT + VAT interoperability |
Single entry point for cross-border tax reporting; no tax at option acquisition if harmonised |
|
|
Implementation path |
Open to enhanced cooperation if needed for depth |
Start corporate-law core, add tax modules after testing |
Corporate law first; tax via coordination/recommendations if unanimity blocks |
The Commission column reflects the published proposal of 18 March 2026 (COM(2026) 321). The text remains subject to amendment during ordinary legislative procedure by Parliament and Council. Adoption targeted for end of 2026.
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Core documents:
Hub & resources:
Core document:
Parliament:
Council: