I'll probably never understand the concept of EU... Look at Luxembourg which was one of the founding members, small country benefiting from offering good tax conditions - however they hate and strongly oppose when someone (outside of EU) does the same.
Then EU uses what you mention, BEPS and blacklists.
Then you have some countries such as France, Italy, Czechia doing random s**t on their own, for example a digital tax targeted
selectively at Google and Facebook, 5-7% of revenue. Probably because the government is running out of options, so just throw a Hail Mary and hope it will work.
Not only it is stupid but it is also hypocritical. Governments pretend to be better than companies but their goal is just the same, more power and more control...
(It reminded me situation between Europe, Russia and USA now in December. EU/Germany made a deal with Russia to import natural gas through a new Nordstream pipeline. USA intervened and imposed sanctions on companies laying the pipeline. Two entities made an international deal and another government (which had nothing to do with it) intervened officially to protect EU's interest because apparently they know better.)
Point is that the more globalized and decentralized the world is, the more difficult it will become to enforce these CFC, BEPS and other rules.