EU rules on administrative cooperation - recast

MEDEF would like to remind about its previous contributions submitted in July 2024 and June 2025, which remain largely valid. As regards the recast of the Directive on Administrative Cooperation (Directive 2011/16/EU DAC), we would recommend focusing on the following key priorities: eliminating reporting obligations that are obsolete or provide limited value, particularly under DAC6, and streamlining overlapping or…

Ledger welcomes the European Commissions initiative to consolidate and simplify the Directive on Administrative Cooperation (DAC). We fully support the objective of reducing administrative burdens and eliminating inconsistencies to improve legal clarity for market participants.

We are pleased to respond on behalf of Marktplaats to the public consultation on the EU Rules on Administrative Cooperation in the Field of Taxation. Please refer to our letter which focuses on the impact that DAC7 has had on our platform, and possible improvements to the framework to improve its effectiveness and proportionality.

We are pleased to respond on behalf of the Deloitte firms in Europe to the European Commission Call for Evidence on the Recast of EU Rules on Administrative Cooperation in the Field of Taxation (DAC Directive 2011/16/EU), and welcome the opportunity input views on this topic. Please refer to our letter for detailed comments in relation to this call for evidence.

We support the objective of simplifying and consolidating the Directive on Administrative Cooperation, but we emphasize that particular attention should be given to the practical implications of DAC8 for the crypto-asset ecosystem. The effectiveness of DAC8 depends less on the breadth of its formal scope and more on whether its obligations are realistically enforceable.

As part of the tax omnibus package, the European Commission plans to propose a recast of European rules on administrative cooperation in the field of taxation (DAC) to make business easier and faster in Europe by reducing administrative burdens and simplifying implementation.

Classifieds Marketplaces Europe (CME), a coalition of European second-hand online marketplaces, including Adevinta, OLX, Vend, Vinted, Wallapop, and CustoJusto, welcomes the opportunity to contribute to the Commissions reflections on the functioning of the Directive on Administrative Cooperation (DAC). We believe that a revision of this framework could significantly improve its effectiveness and proportionality.

The Irish Tax Institute welcomes the opportunity to contribute to the European Commissions evaluation of the possible recast of Council Directive 2011/16/EU on administrative cooperation in the field of taxation (Recast of the DAC).

Ecommerce Europe - the European association representing cross-border digital commerce - gathered feedback from its membership on the Council Directive (EU) 2021/514 on Administrative Cooperation in the field of taxation (DAC7).

We would like to thank the European Commission for the opportunity to provide input in the context of the Call for Evidence on Directive 2011/16/EU on administrative cooperation in the field of direct taxation (DAC), as well as its subsequent amendments. The proposed DAC recast offers numerous opportunities to improve the efficiency of data reporting.

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to review and strengthen the reporting obligations set out under the Directive on Administrative Cooperation in the field of taxation (DAC).

KPMG member firms in the European Union are pleased to provide comments on the European Commissions public consultation "EU rules on administrative cooperation in the field of taxation recast". We welcome the European Commission's initiative to clarify, simplify and improve the functioning of EU rules on administrative cooperation in the field of taxation, with the aim of reducing the administrative burden for…

Palta - Service Sector Employers welcomes the Commissions initiative to simplify and declutter tax legislation, by recasting the Directive on Administrative Cooperation (DAC). Administrative burden is a major cost for companies operating in the EU and also a barrier when trying to enter the Single Market. Please see our detailed comments in the attached file.

EBIT's Members thank the European Commission for this opportunity to provide feedback on its public consultation on a possible recast of the Directive on Administrative Cooperation in the field of direct taxation (DAC).

The Federal Chamber of Tax Consultants welcomes the opportunity to respond to the European Commission’s invitation to submit comments on the recast of the rules on administrative cooperation in the field of taxation. Please see our comments in the attached file.

Filed in German · English published by the European Commission

The Estonian Chamber of Commerce and Industry supports the European Commission’s initiative to recast the Directive on administrative cooperation in the field of taxation. We consider it a priority to simplify the current framework and reduce fragmentation.

Filed in Estonian · English published by the European Commission

The European Association of Co-operative Banks (EACB) welcomes the opportunity to comment on the European Commission's call for evidence on the recast of EU rules on administrative cooperation in the field of taxation (DAC). On DAC consolidated text: In our opinion, consolidating DAC 1 to 9 does not address the objective of reducing administrative burdens. DAC 1 to 9 have already been transposed into national law.

Zusammenfassung Bitkom unterstützt das Vorhaben der Europäischen Kommission, die Richtlinien über die Zusammenarbeit der Verwaltungsbehörden im Bereich der Besteuerung (DAC) in einer Neufassung zu konsolidieren und zu vereinfachen. Ziel muss eine klarere, effizientere und kostensparende Umsetzung sein.

This submission provides targeted feedback on the operational impact of DAC7 for digital platforms. While supporting the objectives of tax transparency and administrative cooperation, it highlights challenges related to low reporting thresholds, the inclusion of non-commercial sellers, limitations in validating seller data, and overlapping due-diligence obligations, as well as potential unintended effects on the…

Invest Europe welcomes the opportunity to contribute to the evaluation and recast of the EU Directive on Administrative Cooperation in taxation (DAC), with a particular focus on DAC6 and the potential integration of the Unshell Directive (ATAD3) into a simplified framework.

Banks are central to the functioning of the Automatic Exchange of Information (AEOI) system, as they carry out due diligence and reporting obligations that enable tax authorities to combat tax evasion. Global and EU tax transparency rests on a dense framework combining FATCA, the OECDs Common Reporting Standard (CRS), the Crypto-Asset Reporting Framework (CARF), and the EU Directive on Administrative Cooperation…

BusinessEurope welcomes the Commissions initiative to recast the Directive on Administrative Cooperation (DAC) and strongly supports the objective of delivering measurable reductions in administrative burden while preserving effective tax transparency. Successive amendments (DAC1DAC9) have resulted in fragmentation, duplication and disproportionate compliance costs, particularly under DAC6.

Booking.com welcomes the European Commission's simplification agenda and the intention to address regulatory complexities, overlaps and fragmentation, including those raised in the application of the Directives on Administrative Cooperation (DAC). We believe there is an opportunity to streamline requirements, thus also creating the conditions to deliver more effectively the desired policy outcomes.

This submission by EuroCommerce responds to the European Commissions consultation on the Directive on Administrative Cooperation (DAC). Based on practical implementation experience across multiple DAC regimes, EuroCommerce observes recurring structural issues that generate disproportionate compliance burdens without corresponding benefits from enforcement.

The European Round Table for Industry (ERT) appreciates the European Commission's initiative to review and recast the Directive on Administrative Cooperation (DAC). We fully endorse the Commissions political objective, outlined in the Long-Term Competitiveness Communication, to reduce administrative burdens associated with reporting requirements by 25%.

ETAF welcomes the DAC recast as a continuation of the Commissions work following its evaluation of the DAC framework and as part of its wider objectives to simplify EU legislation and reduce reporting-related administrative burdens for businesses, particularly small and medium-sized enterprises (SMEs).

The opinion of the German Association of Tax Consultants (Deutscher Steuerberaterverband e.V. – DStV) is attached in DE/EN version: Summarising: The DStV reiterates its criticism of the DAC 6 reporting requirements. These have not produced the desired results, are not suitable for achieving the objectives and are disproportionate.

Filed in German · English published by the European Commission

Privacy First (https://privacyfirst.nl/en/) is a Dutch non-profit organisation with financial privacy as one of its focus areas. We understand the necessity to clarify, simplify and improve the functioning of EU rules on administrative cooperation in the field of taxation, that should also provide a better protection of the financial human rights of the citizens of the EU.

This contribution is submitted by CFE Tax Advisers Europe in response to the European Commissions public consultation and Call for Evidence on the recast of the Directive on Administrative Cooperation in the field of taxation (DAC). The submission sets out CFEs views, technical observations and recommendations based on practical experience with the application of the DAC framework across Member States.

The below is being provided by the Malta Institute of Accountants after having consulted with its members. 1. General remarks We welcome the European Commissions initiative to recast and consolidate the Directive on Administrative Cooperation (DAC). The existing framework has become fragmented and complex, creating unnecessary administrative burdens for taxpayers, intermediaries, and tax administrations.

The successive amendments to the Directive on Administrative Cooperation in the field of taxation (DAC) have resulted in an increasingly complex framework, imposing a significant compliance burden on businesses.

INREV welcomes the European Commissions review of the Directive on Administrative Cooperation (DAC) and supports the objective of effective administrative cooperation to combat tax abuse, while stressing the need for greater proportionality, legal certainty and administrative efficiency.

This initiative is an integral part of the Commission’s efforts to simplify EU law. It aims to clarify, simplify and improve the functioning of EU rules on administrative cooperation in the field of taxation, thereby reducing the administrative burden for the relevant stakeholders and supporting the growth and competitiveness of the EU.

Filed in Italian · English published by the European Commission

The European Commission should build a long-term tax simplification program from current reform efforts. A focus on sustained growth, meaningful metrics, and institutional capabilities that keep simplification a focus in future regulatory efforts should underpin the decluttering agenda.

We welcome the initiative to simplify and clarify reporting obligations under the Directive on Administrative Cooperation (DAC), and potentially consolidate various provisions into a single Directive for greater clarity. We note that recasting the DAC could help reduce the reporting burden on large companies and SMEs, as well as tax administrations.

· We welcome the initiative to simplify and clarify reporting obligations under the Directive on Administrative Cooperation (DAC), and potentially consolidate various provisions into a single Directive for greater clarity. · We note that recasting the DAC could help reduce the reporting burden on both large companies and SMEs, as well as tax administrations.

We welcome the EC initiative to gather additional feedback on the possible recast of the DACs. As a general comment, in our view, there is room for simplification and alleviation of administrative burden in order to enhance compliance and increase competitiveness for EU companies. The main hurdles we face are as follows: We observe an unbalance between compliance costs and benefits obtained by tax administrations.

As a supplier of solutions for businesses to collect, verify and report the required information for the DAC7 report we see a that the lack of communication by the local tax authorities, unclear thresholds for alternatives methodes provided by the local tax authorities create a lot of confusion with companies.

The data to be reported for the different DAC reports shall be limited to what is necessary and a fully automated digital process shall be established between all European and national authorities involved across the EU. The reported data must also be analysed.

Filed in German · English published by the European Commission