Comment to Question no. 3 An immediate mandatory inclusion of smaller firms into the scope of the Directive is risky because: a) it requires important transition costs (which larger firms can bear more easily) at a time when such rules are still new and probably may doubts as far as their application is concerned exist.
AAI
AIDC - Associazione Italiana Dottori Commercialisti
Industry association · Italy
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts — staff, costs, accreditations — are not available for it.
2
positions filed
in the 583 files tracked
2
legislative files
of 583 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
AIDC - Associazione Italiana Dottori Commercialisti filed 2 positions between 11 Oct 2022 and 25 Jan 2023, across 2 of the 583 legislative files tracked here, attaching a full position paper 2 times.
2022 · 1 filed2023 · 1 filed
What they argued
The European Commission has recently published a “Call for evidence” to ensure the role and responsibility of “Enablers” or “facilitators” in structuring and creating evasive and aggressive tax schemes for their clients. The issue has long been discussed in the field of international taxation two to the relevance that certain Enablers had in the collaboration with taxpayers involved in evasive or aggressive schemes.
Filed in Italian · English published by the European Commission
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
Showing 5 of 7.
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