European Trust and Cooperation Approach – ETACA Pilot Project for MNEs

In July 2020, the European Commission published the Action Plan for fair and simple taxation supporting the recovery strategy, in which it committed to developing, together with interested Member States, an EU Cooperative Compliance framework, commonly referred to as ETACA (European Trust and Cooperation Approach). The objective of this non-legislative initiative is to facilitate and promote tax compliance by fostering greater cooperation, trust, and transparency between taxpayers and tax administrations, as well as among tax administrations themselves.

The initiative also aims to establish a clear, EU-wide framework for preventive dialogue between tax administrations and business taxpayers. This dialogue is intended to enable tax administrations to conduct high-level risk assessments of the transfer pricing policies adopted by large multinational enterprises (MNEs). As a result, companies benefit from greater certainty in their international operations, helping to prevent double taxation and reduce tax compliance costs.

Published in October 2021 and subsequently revised in May 2025, the ETACA Guidelines are intended for interested taxpayers and participating tax administrations. They aim to support these stakeholders during the ETACA Pilot phase and, ultimately, to facilitate the transition to a more permanent implementation of the ETACA Program.

First Pilot Phase

The ETACA Pilot phase began with the launch of its First Pilot in November 2021, involving fourteen Member States as part of the ETACA Steering Group and three volunteering MNEs, in order to test the practicality and effectiveness of the Guidelines.

On 15 and 16 April 2024, the European Commission hosted a workshop with various private sector stakeholders — including the three volunteering MNEs — and representatives from eighteen Member States’ tax administrations. The primary objective was to gather feedback and lessons learned from the First Pilot and to discuss next steps for the ETACA initiative, particularly the planned launch of a Second Pilot in 2025.

As of today, seventeen Member States have expressed their willingness to participate in the Second Pilot of the ETACA Program. If you are interested in receiving more information or taking part in the Second Pilot, please refer to the contact details below.

Second Pilot Phase

Following the First Pilot Phase, EU Member States, together with the European Commission, are preparing to launch the Second Pilot of ETACA. On 24 September 2025, the European Commission organized a stakeholder conference to provide further information on participation in the Second Pilot, including details about the initiative and its benefits.

Find below the slides from the event:

From now on, interested MNEs are encouraged to contact the Tax Administration of the UPE’s tax residence and submit an initial application. Further details on the application process can be found in the ETACA Guidelines.

Contact

Flyer promoting ETACA for large multinational enterprises