Simplification of the Union framework on direct taxation

We welcome the opportunity to provide you with comments regarding the following topics: Dispute Resolution: The proposal significantly limits procedural delays and makes it harder for Member States to refuse participation or obstruct access to dispute resolution mechanisms. However, the proposal does not create a new hard deadline forcing authorities to decide within a specific shorter period.

EPRA represents more than 290 members across the listed real estate ecosystem. Its corporate members hold approximately 1.049 trillion in real estate assets globally, including 765 billion in Europe. EPRAs mission is to promote, develop, and represent the European publicly listed real estate sector.

The Irish Tax Institute welcomes the opportunity to provide feedback on the European Commissions proposal for a Council Directive amending Directives 2003/49/EC, 2009/133/EC, 2011/96/EU, (EU) 2016/1164, (EU)2017/1852, (EU) 2025/50 as regards the simplification of the Union framework on direct taxation and supporting growth and competitiveness of the EU (i.e. Tax Omnibus Directive).

Dear Sir/Madam, 1. The WKÖ warmly welcomes the abolition of the minimum holding ratio for interest, royalties and dividends. We also urge harmonisation of withholding tax relief procedures, evidence requirements and forms within the EU. In addition, in the interests of the location of the business, provision should be made for a much earlier application than that on 1 January 2037. 2.

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DigitalTrade4.EU proposes a targeted approach to reducing cross-border tax compliance burdens under COM(2026) 560 through the use of reliable, machine-readable electronic evidence and interoperable digital procedures. The European Business Wallet could support business identification, representation and the secure exchange of supporting information between companies and tax authorities across Member States.

Following the public call for evidence with regard to the envisaged proposal for an omnibus directive in direct taxation, Loyens & Loeff N.V. would like to express its gratitude for the opportunity to submit feedback and refers to the attached document.

The Omnibus package on taxation is part of the Commission’s efforts to simplify EU law and cut red tape for businesses. The aim is to boost competitiveness and improve the functioning of the EU legislative framework on corporate taxation (EU rules on parent and subsidiary companies, interest and royalties, mergers, prevention of tax avoidance and dispute resolution mechanisms).

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Philea provides feedback on the European Commissions consultation aimed at simplifying EU direct taxation rules, highlighting challenges faced by philanthropic foundations due to fragmented tax frameworks and urging for improved cross-border recognition of public benefit status for tax purposes of public benefit foundations and corporate donors .

We welcome the opportunity to contribute to the European Commissions Call for Evidence on the Omnibus on Taxation. We have prepared the attached Position Paper which outlines the feedback from our members who are Chartered Tax Advisers that provide tax services and business expertise to thousands of Irish owned and multinational businesses, as well as to individuals, in Ireland and internationally.

The International Securities Lending Association (ISLA), the International Swaps and Derivatives Association (ISDA) and the Association for Financial Markets in Europe (AFME) are grateful for the opportunity to respond to the European Commissions Call for Evidence on the Taxation Omnibus highlighting the need for greater harmonisation and simplification with respect to the meaning and application of beneficial…

Under the Parent-Subsidiary Directive (Council Directive 2011/96/EU), dividend payments are exempt from withholding tax, while dividends received are exempt from income tax, provided, inter alia, that the receiving legal person has a participation of at least ten per cent (10 %) in the value or number of shares or in the basic capital or in the rights giving entitlement to profits or voting rights of the…

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EBIT's Members welcome the European Commission's 'Call for Evidence on simplifying EU rules on direct taxation - omnibus and appreciate another opportunity to provide our comments and contribute to this important and much-needed initiative. Please find enclosed EBIT's response.

France Assureurs welcomes the opportunity to share the feedback of the French insurance industry on the European Commissions initiative to simplify the existing EU legal framework for direct taxation and boost competitiveness in the internal market.

Dear Sir/Madam, We welcome the European Commissions Call for Evidence on the forthcoming Tax Omnibus initiative, which aims to introduce targeted changes to EU direct tax legislation. MEDEF has actively contributed to all public consultations conducted in 2025 in the context of the Commissions simplification agenda. We refer to our previous submissions, which remain largely valid.

ISLA, ISDA & AFME Response to EU Tax Omnibus Call for evidence regarding Beneficial Ownership Tax Omnibus Call for evidence: Beneficial ownership The International Securities Lending Association (ISLA), the International Swaps and Derivatives Association (ISDA) and the Association for Financial Markets in Europe (AFME) are grateful for the opportunity to respond to the European Commissions Call for Evidence on the…

KPMG member firms in the European Union are pleased to provide comments on the European Commissions public consultation Simplifying EU rules on direct taxation omnibus. We welcome the European Commission's initiative to streamline, enhance and clarify the corporate tax directives and the Tax Dispute Resolution Mechanisms Directive, with the aim of supporting the competitiveness of the EU.

We are pleased to respond on behalf of the Deloitte firms in Europe to the European Commissions Call for Evidence on Simplifying EU rules on direct taxation omnibus. We welcome the opportunity to contribute to this important initiative. This letter outlines our key recommendations to achieve genuine simplification, greater coherence, and improved competitiveness across the EUs direct tax framework.

As the representative body for mutual and cooperative insurance undertakings in the EU, AMICE supports the Commissions goal of simplifying the corporate tax framework and reducing administrative burdens. We therefore welcome the intention to streamline existing corporate tax directives.

LAfep, the Association of Large French Companies, welcomes this call for evidence, which appears appropriate for reassessing the necessity, consistency, and effectiveness of the provisions set out in these various Directives.

We appreciate the opportunity to submit these comments on behalf of EY in response to the European Commissions Call for Evidence on policy options to simplify the existing direct tax framework of the European Union and enhance competitiveness within the internal market.

Fi-Group welcomes the European Commissions initiative to simplify the EUs direct taxation framework. The Call for Evidence highlights long standing challenges affecting businesses across the Single Market, including high administrative costs, burdensome procedures, outdated and overlapping rules, and divergences in interpretation created by the flexibility and inconsistency in how existing directives are implemented…

The National Foreign Trade Council (the NFTC) is pleased to provide written comments on the call for evidence on Simplifying EU rules on direct taxation. The NFTC, organized in 1914, is an association of U.S. business enterprises engaged in all aspects of international trade and investment. Our membership covers the full spectrum of industrial, commercial, financial, and service activities.

CFE Tax Advisers Europe has prepared an Opinion Statement on the European Commissions Call for Evidence on the Omnibus on Taxation, which aims to streamline and modernise key EU corporate tax directives, including the Anti-Tax Avoidance Directive (ATAD). CFE welcomes the Commissions focus on simplification and supports the objective of improving the coherence and efficiency of the EU direct tax framework.

The Commissions initiative to simplify EU law in direct taxation, with its focus on reducing administrative burdens, eliminating outdated/overlapping rules, and improving consistency and application across Member States, is urgently needed to ensure the EU's competitiveness.

The outermost regions (ORs) are European territories with permanent structural constraints that cannot be corrected by the uniform implementation of common policies. Experience shows that, without specific adaptations, European policies generate effects that run counter to the objectives of cohesion, competitiveness and strategic autonomy.

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Pearle*-Live Performance Europe, representing over 13,000 organisations and companies in the music, performing arts, and live events sectors, welcomes the Commissions objective of simplifying and clarifying EU tax rules to reduce administrative burdens and improve the business environment in Europe. For the live performance sector, tax complexity is not merely a technical compliance issue.

The Association for Financial Markets in Europe (AFME) welcomes the opportunity to respond to the European Commissions call for evidence on the forthcoming Omnibus on Taxation. Further details are provided in our attached feedback, including a joint contribution with ISLA and ISDA, which highlights the need for greater harmonisation and simplification with respect to the meaning and application of beneficial…

The Italian Banking Association (hereinafter ABI) represents and promotes the interests of almost 600 Italian banks and financial intermediaries. ABI welcomes the opportunity to comment on the European Commission Call for Evidence on Omnibus on Taxation. Please find attached our suggestions aimed at ensuring that this initiative fosters an EU tax framework that supports the competitiveness of EU businesses.

The Central Association of German Crafts (ZDH) represents the interests of around 1 million craft businesses in Germany, employing around 5.6 million people. The attached opinion sets out practical approaches on how to significantly reduce the burden on craft businesses by making the necessary adjustments. The proposals go beyond simplifying EU rules in the area of direct taxation.

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The EU Commission's calls for simplification of the tax system are reasonable, given the administrative burden of navigating 27 distinct national tax systems. However, it is important to consider carefully revisions to directives such as ATAD in order not to undermine their policy objectives. Many proposals framed as simplifications risk creating more space for profit shifting and aggressive tax planning.

The European Banking Federation (EBF) stresses that, in an increasingly fragile economic and geopolitical context, simplifying the EUs corporate income tax framework is an urgent priority. Current rules impose disproportionate compliance burdens on EU businesses, undermining their global competitiveness.

BUSINESSEUROPE is Europe's largest business organisation and a leading advocate for growth and competitiveness at the EU level. Please find attached our detailed views on how the Tax Omnibus should deliver tangible simplification in practice. We remain ready to engage constructively to ensure that this initiative delivers meaningful simplification and a more effective EU tax framework.

Deutsche Börse Group (DBG) welcomes the opportunity to provide feedback on the European Commission's Call for Evidence regarding the 'Omnibus' initiative to streamline tax rules. We support the goal of improving the business environment in the EU by reducing administrative burdens and enhancing tax certainty.

The Malta Institute of Accountants (MIA), the national professional body representing the accountancy profession in Malta, actively promotes high professional standards and contributes to public policy discussions across a broad range of areas relevant to the profession and the wider economy.

Heimstaden is a European residential real estate company operating across several EU/EEA countries. Our business is based on long-term ownership and management of residential investment properties, supported by stable rental income and financing structures aligned with the long-term nature of these investments.

Please see attached file of answers on behalf of President Elbano de Nuccio of the National Council of Chartered Accountants and Accountants. CNDCEC is the Professional organisation that in Italy represents Cpa (members registered with the professional role are engaged in accounting, auditing, tax, insolvency, corpporate advice and related activities).

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As a provider of audit & assurance, tax, advisory and consulting services in over 100 countries and territories, including 26 European member states, Forvis Mazars welcome the opportunity to contribute to the European Commissions call for evidence on the Tax Omnibus.

On behalf of Polska Izba Nieruchomości Komercyjnych (Polish Commercial Real Estate Association; PINK), we welcome and support the Commissions broader Omnibus on taxation initiative aimed at simplifying some of the EU direct tax directives. We share the objective of reducing administrative frictions, improving legal certainty and facilitating cross border investment.

Insurance Europe welcomes the European Commissions initiative to simplify EU direct taxation rules. Greater legal certainty and reduced administrative burdens are essential for ensuring that the EU tax framework remains efficient, competitive and proportionate. The attached annex sets out detailed technical proposals; the key recommendations are summarised below.

Back Market welcomes the Commission's Omnibus on taxation initiative but urges the extension of its scope beyond corporate direct taxation to include critical VAT issues that create significant administrative burdens for digital marketplaces.

The real estate industry is particularly affected by the Interest Limitation Rule due to its struc-turally capital-intensive orientation and long-term debt financing structures. The current design of the Interest Limitation Rule acts less as a targeted anti-abuse instrument but rather as a systematic investment barrier.

Driven by OECD initiatives, the EU tax framework has been significantly reinforced. The DAC has expanded, the anti tax avoidance directive (ATAD) introduced a comprehensive anti-avoidance corpus, and the Pillar Two rules were incorporated into EU law adding another layer of obligations and compliance requirements. These rules are creating significant level playing field challenges.

The European Federation of Accountants and Auditors for SMEs welcomes the European Commissions commitment to reducing administrative burdens for SMEs and the European Councils tax simplification agenda to enhance EU competitiveness, and is pleased to provide feedback in this context. Please see attached document

The European Association of Cooperative Banks (EACB) welcomes the opportunity to provide feedback on the European Commissions call for evidence concerning the simplification of EU rules on direct taxation. The EACB believes that tax policy should ensure legal certainty, proportionality and administrative simplicity for businesses.

Invest Europe welcomes the European Commissions initiative to simplify EU rules on direct taxation through an Omnibus package. While recent EU tax initiatives have pursued important policy objectives, their cumulative impact, combined with divergent national implementation, has created significant legal uncertainty and administrative burdens.

ETAF welcomes the Tax Omnibus initiative as an important step towards simplifying the EU's direct tax framework and supports its ambition to reduce compliance costs for businesses while preserving the anti-avoidance objectives the Directives were designed to serve.

The Austrian Economic Chamber (WKÖ) represents the interests of more than 590.000 member companies. As part of this consultation, the WKÖ responds to the concerns of its members and advocates a workable, competitive and low-bureaucratic framework.

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Unilever welcomes the Commissions Omnibus on Taxation as a timely chance to simplify European Union tax rules. In the current economic environment, tax policy is a strategic mechanism to attract investment and support innovation.

The European Association for Investors in Non-Listed Real Estate Vehicles (INREV) represents the European non-listed real estate investment industry. INREV supports the development of professional standards, transparency and best practice across the sector through research, industry guidance and policy engagement.

The United States Council for International Business (USCIB) is a multi-industry trade association that promotes open markets, competitiveness and innovation, sustainable development and corporate responsibility. Our members include multinational companies and professional services firms from every sector of the economy with operations in every region of the world.

The Omnibus on taxation legislative proposal aims at enhancing EUs competitiveness. EU competitiveness depends on many factors, including the capacity of states to invest in education and training, social protection systems, decarbonisation and circularity, research and innovation. Without effective, clear, harmonised and transparent taxation rules, those investments are not possible.

Legnica, 27 January 2026 ZPPM/15S/III/2026 Directorate-General for Taxation and Customs Union (DG TAXUD) Position Paper of the Employers’ Union Polska Miedź on the public consultation on the simplification of EU rules on direct taxation Omnibus package on taxation (Ref. Ares(2026)2265935).

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The German Industry is under significant competitive pressure. Investment decisions are being weighed very carefully, and there is now a clear need for strong, positive signals from policymakers. The forthcoming EU Commissions tax omnibus package presents a valuable opportunity to deliver meaningful relief: reducing administrative burdens, simplifying tax obligations, and eliminating redundant reporting…

As an independent research institute specialised in the empirical analysis of tax avoidance and profit shifting, the International Tax Observatory regularly examines how tax rules operate in practice and how firms respond to them. This submission provides evidence-based input for the upcoming Taxation Omnibus, drawing on a forthcoming publication.

CALL FOR EVIDENCE CONTRIBUTION OF FRANCE POST MARCHE We thank the Commission for the opportunity to provide our feedback about the omnibus on taxation, and we welcome the Commissions efforts to simplify EU law, to boost competitiveness and improve the EU legislative framework for corporate taxation.

Oxfam supports the EUs effort to simplify its directives related to direct taxation but express concerns against using simplification to weaken anti-avoidance rules and narrowing Member State's tax base. The Omnibus should close loopholes, not widen them. You will find our full contribution in the attached document. This document covers the following points : 1.

AICPA & CIMA together as the Association of International Certified Professional Accountants welcome the opportunity to comment on the simplification of the EU rules on direct taxation. With nearly 600,000 members in over 150 countries globally, as well as a strong membership base in the EU, our comments have been shaped by member insights, and in particular the contribution of volunteer members of the AICPA…

Dear Sir / Madam, Attached please find feedback by The Malta Chamber of Commerce, Enterprise and Industry. We acknowledge the Commissions efforts to strengthen Europes attractiveness and competitiveness, in part, through this omnibus on taxation initiative.

Today, private waste management companies and other actors within the circular economy are confronted with an uneven level playing field when it comes to the taxation of economic activities in relation to public enterprises and manufacturers of the primary industry. This applies in particular to an unequal treatment with regard to VAT compared to public waste management companies.

The European Commissions tax simplification agenda and the forthcoming Omnibus on Taxation should identify priority measures that reduce compliance burdens, eliminate redundancies, and enhance EU competitiveness. For BMW Group the two most important items would be The elimination of (German) CFC rules (example: would avoid monitoring substance in holding companies of BMW Group).

We strongly support the objective of ATAD of combatting tax evasion and international tax planning. However, the negative impact the directive has on strategic investments and the one-size-fits-all character of certain exemptions may have led to a situation where the disadvantages of the directive outweigh the advantages for certain categories of entities that were never its intended target.

The Nordic finance sector in Denmark, Finland and Sweden would like to give the following feedback on the Have Your Say Simplifying EU rules on direct taxation omnibus. At the outset, we would like to emphasize the importance of the forthcoming Tax Omnibus for the competitiveness of European companies.

The GdW Bundesverband deutscher Wohnungs- und Immobilienunternehmen e.V. (Federal Association of German Housing and Real Estate Companies), as the largest German umbrella industry association, represents some 3000 municipal, cooperative, church, private, provincial and federally owned housing companies throughout Germany and at European level.

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German Tax Advisers (GTAs) are an association of the Federal Chamber of Tax Consultants KdöR (BStBK) and the German Association of Tax Consultants e.V. (DStV) at EU level. Together, they represent the entire German profession vis-à-vis the EU institutions.

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The Austrian Chamber of Tax Advisors and Public Accountants (Kammer der Steuerberater:innen und Wirtschaftsprüfer:innen, KSW) is the professional body for more than 6,300 tax advisors and almost 2,000 public accountants as well as more than 4,300 professionals in training in Austria.

This contribution to the Call for Evidence on the EU Tax Omnibus outlines selected simplification measures aimed at improving the functioning of the EU direct tax framework, while preserving effective anti-avoidance safeguards.

Caisse des Dépôts et Consignations (CDC), as a public financial institution with a mandate to support long-term investment and public interest missions in France, welcomes the European Commission initiative to simplify and modernize the EUs corporate tax directives framework through the proposed Taxation Omnibus.

The European Round Table for Industry (ERT) strongly supports the European Commissions efforts to simplify EU legislation with respect to taxes. At a time of slow economic growth and intensifying global competition, the EU must place business competitiveness at the centre of its policy agenda.

Dear Sir or Madam: We welcome the European Commission's efforts through this initiative aimed at achieving the objectives of simplification and enhancing the competitiveness of the European Union. As Telefónica Group, we are pleased to submit our feedback to the European Commissions Call for Evidence on Simplifying EU Rules on Direct Taxation (Omnibus) and appreciate the opportunity to contribute to the discussion…

(1) The proposed simplifications in the field of direct taxation are welcome as the current framework is administratively very complex for businesses. However, focusing the upcoming Omnibus tax package only on selected directives is unlikely to be sufficient to achieve the ambitious objective of reducing administrative burdens for businesses.

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Abertis, international benchmark operator in the management of high-capacity toll roads and intelligent mobility solutions, together with its European subsidiaries in Spain, France and Italy and its broader group companies active across the Americas and Asia, welcomes the opportunity to contribute to the European Commissions Call for Evidence on the Omnibus on Taxation.

The European Real Estate Association (EPRA) is the voice of Europes listed real estate companies, their investors, and suppliers. With more than 290 members covering the entire spectrum of the listed real estate industry, EPRA represents over EUR 940 billion in real estate assets and 95% of the market capitalisation of the FTSE EPRA Nareit Europe Index.

List of Proposals and Their Justification 1. Ensure a clear hierarchy between CFC rules and Pillar Two Proposals: Allow groups in scope of Pillar Two to deactivate CFC rules. Introduce clear interaction rules to avoid economic double taxation.

Confprofessionali welcomes the European Commission’s initiative, recognising the Omnibus package on taxation as a strategic step towards strengthening the competitiveness of the European economic system and improving the functioning of the single market.

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ACCA welcomes the European Commissions initiative to simplify EU rules on direct taxation. As a chartered global professional accountancy body, ACCA strongly supports efforts to reduce administrative burdens, enhance tax certainty, and ensure a fair and efficient tax environment for organisations operating in the single market.

For reasons of competition, German small and medium-sized enterprises are required to systematically internationalise their activities in order to open up new markets, establish proximity to global customers and build competitive advantages. This necessarily goes hand in hand with the internationalisation of business owners.

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Responding to the invitation to add any comments or suggestions on possible solutions to simplify European Union law and improving the functioning of the EU legal framework for corporate taxation, we wish to submit our proposals. Please find the attached.

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AmCham Belgium welcomes the European Commissions initiative to develop a taxation omnibus package and sees this as a key opportunity to deliver meaningful simplification, coherence, and legal certainty across EU direct tax rules. A streamlined frameworkaligned with the Roadmap for Decluttering, Simplification and Competitivenesswould strengthen the Single Market and enhance the competitiveness of EU based companies.

As a European company operating across multiple jurisdictions within and outside the European Union, Galp welcomes the opportunity to contribute to this Call for Evidence regarding the potential simplification and improvement of the EU corporate taxation framework. Please find attached our feedback for your consideration.

German insurers welcome the plan to "declutter" European tax law. There is considerable potential for simplification. Regulations aimed at preventing tax abuse and low taxation sometimes overlap and increase compliance complexity, in particular with regard to the simultaneous application of the global minimum tax regime and the Anti-Tax Avoidance Directive (ATAD).

Euronexts Submission to the Commissions Call for Evidence on simplifying EU rules on direct taxation As the leading European capital market infrastructure with over 1,800 issuers, Euronext welcomes the opportunity to contribute to the Commissions call for evidence on simplifying EU rules on direct taxation. Todays economic challenges require not only awareness but also decisive action.

Dear Sir/Madam, The European Savings and Retail Banking Group (ESBG) welcomes the opportunity to comment on the Commissions call for evidence on simplifying EU direct taxation rules and submits the following remarks. Article 4(3) of the Parent-Subsidiary Directive allows Member States to deny the deduction of participation-related expenses, with a flat-rate cap of 5% of dividends.

In-House Tax Forum (IHTF) welcomes the opportunity to comment on the Omnibus on taxation initiated by the EU Commission. IHTF supports the Commissions objective of simplifying EU tax legislation, reducing administrative burdens, and enhancing legal certainty for businesses and tax administrations.

We write to clarify that post-consumer PET flakes should not be subject to Commission Implementing Regulation (EU) 2025/1748, as they do not constitute a like product within the meaning of Article 2(c) of Regulation (EU) 2016/1037. The product under review and subject to sampling in the investigation was PET resin (chips). The Union producers identified in the Regulation are: Indorama Ventures Poland Sp.

To whom this may concern, PHOENIX group welcomes the European Commissions intension to simplify EU rules on direct taxation with the overarching goal of reducing administrative burden and inducing business growth across the EU. In our capacity as the largest distributor of critical medicines in Europe, we are highly qualified to contribute to this policy process and share our position (please see attached).

In response to the call for evidence regarding simplification of taxes to support the enhancement of competitiveness in the internal market, without undermining the important policy objectives of the Directives concerned, it's important to also keep in mind and discuss how we can align fiscal incentives with the goals of an inclusive circular economy.

I suggest DG TAXUD offers a few alternatives to the policymakers. It is not a good idea to fixate only iteration of the current complex set of CIT rules, which cannot result in any serious simplification, and being completely blind to the alternatives. A serious alternative is a common tax base (CTB) that mostly copies the successful Estonian CIT system. 1.

Current directives and regulations mainly tackle large enterprises, and aim for preventing tax avoidance. Initiatives for reducing administrative overhead for small businesses are missing. To support cross-border cooperation, we would appreciate if the tax base in direct taxation and the practical method of filing income taxes could be (voluntarily) harmonized. By introducing a possibility for small businesses (e.g.