Fortum’s views on the Commission’s Omnibus initiative for tax simplification

Our contribution to the Call for Evidence reflects Fortum’s strategy to enable the clean energy transition and strengthen security of supply through long-term, capital‑intensive investments—while operating with high standards of responsibility, transparency and compliance.

As a Nordic energy company with long‑cycle infrastructure assets, Fortum recognizes the need for a tax framework that is predictable, coherent and investment‑friendly. We therefore support the Commission’s objective to modernise and simplify EU direct tax rules, reduce unnecessary overlaps, and better align legislation with business reality—particularly in the context of Pillar Two.

Our response is grounded in our Board‑approved tax principles, long-standing tax transparency (our Tax Footprint published annually since 2012), and independent Fair Tax accreditation, where Fortum achieved top‑tier recognition in 2025. Our core message is that effective anti‑avoidance measures and responsible business conduct can go hand in hand.

Against this background, Fortum highlights several areas where targeted simplification and improved coherence would support investment, competitiveness and Europe’s energy security.

Key points raised by Fortum include:

• Targeted, risk-based anti-avoidance (ATAD): focus on genuinely abusive structures, not ordinary business activity, reducing unnecessary complexity and cost.
• Prevent double taxation and improve legal certainty: profits should be taxed once; consistent application across Member States supports competitiveness and cross-border investment.
• Update CFC rules for Pillar Two world: reduce overlaps, optionality, and duplicate reporting.
• Refine the Interest Limitation Rule to reflect infrastructure reality: ensure arm’s-length internal and external financing are treated consistently and that rules don’t unintentionally deter critical energy investments.
• Stronger dispute prevention and early certainty tools: faster clarity helps unlock investment decisions and supports stable revenues.
• Lower administrative burden overall: simpler, coherent rules strengthen Europe’s investment climate and, by extension, energy security.

Fortum advocates a proportionate EU tax framework that safeguards public revenues while enabling the long-term investments Europe needs for a resilient, competitive and decarbonised energy system.

For more information please contact:

Reijo Salo, VP, Group Tax: reijo.k.salo@fortum.com
Anna Wrzesinska, Director, Group Tax: anna.wrzesinska@fortum.com