Opinion Statement CFE 3/2025 on the European Commission Consultation Concerning the “28th Regime” for Start-Ups and Scale-Ups

Key Points

• The opinion statement aims to address the EU's consultation regarding a potential 28th Regime for start-ups and scale-ups.
• Submission of opinion statement to EU institutions on September 30, 2025.
• Evaluation of the current state of tax fragmentation and compliance burdens for start-ups.
• Recommendations for a single tax filing interface and harmonized documentation.
• CFE supports a unified EU entity if it decreases tax fragmentation.
• Recommends digital tools to enhance investor confidence in start-ups.
• Highlights the need for safe harbours in transfer pricing and incentives for R&D.

Abstract