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: 24.02.2026
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Dimension |
“28th regime” |
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Regime 0 (Bruegel) |
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|---|---|---|---|---|---|
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Harmonisation scope (corporate / labour / tax / insolvency) |
Public messaging suggests a “single set of rules”; exact scope will depend on the final draft |
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 |
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|
Entry criteria (open vs selected) |
Unknown until draft; consultation materials focus on startups/scaleups & innovative firms |
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) |
Not final; recurring theme is “digital-by-default” and simplification |
EU-level central registry + dashboard |
EU-level one-stop digital registry concept (“Hub0”) |
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ESOP / equity taxation principle |
Frequently mentioned as pain point; outcome unknown |
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 |
Unknown until draft |
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 |
Unknown until draft |
Generally pro “operate anywhere” principle; details in proposal |
Explicit: Regime 0 firms should be treated like national firms; no discrimination |
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Dimension |
Bruegel (Regime 0) |
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ETAF |
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|---|---|---|---|---|
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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 |
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|
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 |
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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 is provisional: until the draft regulation/directive is published, comparisons should be read as “direction of travel”, not final design.
The biggest “fork in the road” is scope (startup-only vs broader) and how much gets harmonised vs kept national (labour/tax/insolvency).
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Link map
Bruegel “Regime 0” page:
https://www.bruegel.org/policy-brief/regime-0-europe-wide-in...
Bruegel “Regime 0” PDF:
https://www.bruegel.org/sites/default/files/2025-12/PB%2033%...
EU–INC homepage:
EU–INC proposal hub:
European Parliament legislative train (28th regime file):
https://www.europarl.europa.eu/legislative-train/theme-a-new...
Commission work programme 2026 (EUR-Lex):
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A...
European Parliament brief (backgrounder on 28th regime):
https://www.europarl.europa.eu/RegData/etudes/BRIE/2025/7792...