Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
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.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Interested party: Association NATIONALE DES SOCIETES BY ACTIONS (ANSA) 39 Rue de Prony 75017 PARIS FRANCE Number of the Transparency Register of the European Union: 236569017571-35 national corporation by shares (ANSA) is pleased to note that the public consultation concerns the establishment of a new EU system to avoid double taxation and prevent abusive tax practices in the field of withholding taxes.
Filed in French · English published by the European Commission
The EBF welcomes efforts at simplification and digitisation of withholding tax processes within the Union. Slow and complex withholding tax reclaim processes remain barriers to efficient investment. A simple, swift, and safe system would encourage intra-union and foreign investment. Nevertheless, the proposed rules remain complex and would require significant due diligence and reporting.
In the public consultation held in September-October 2021 on this topic and in which it participated, ANSA was biased in favour of balanced, realistic measures with reduced budgetary effects. Therefore, the measures presented under the aegis of the Commission in the proposal for a directive of 11 May 2022 (COM (2022) 216 final) give rise to the most complete misunderstanding on our part, as they combine financing…
Filed in French · English published by the European Commission
The EBF agrees with the over-arching goal of mitigating the tax induced debt-equity bias in corporate investment decisions to render financing more accessible to EU business and to promote the integration of national capital markets into a genuine single market. However, in order to promote economic growth and achieve the goals of the proposal, we recommend the following changes.
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