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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.

DEL
Deloitte

Company · Belgium

9
files engaged
of 583 tracked
10
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
CTA
CFE Tax Advisers Europe

Other · Belgium

12
files engaged
of 583 tracked
15
positions filed
in those 583 files
2
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €100K+ a year · in the register since 2008

Files both filed on (8)

Simplification of the Union framework on direct taxation · Business in Europe: Framework for Income Taxation (BEFIT) · New EU system for the avoidance of double taxation in the field of withholding taxes · Debt equity bias reduction allowance (DEBRA) · EU rules on administrative cooperation - recast · Fighting the use of shell entities and arrangements for tax purposes · Tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in the European Union · Minimum level of taxation for large multinational groups

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.

Simplification of the Union framework on direct taxation

Deloitte · filed 30 Mar 2026 · source

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.

CFE Tax Advisers Europe · filed 30 Mar 2026 · source

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.

Business in Europe: Framework for Income Taxation (BEFIT)

CFE Tax Advisers Europe · filed 26 Jan 2023 · source

CFE Tax Advisers Europe has issued an Opinion Statement on the European Commission Public Consultation on the Introduction of a New Corporate Taxation System in Europe. The European Commissions plans to overhaul Europes business taxation rules by introducing a single corporate tax rulebook, known as the Business in Europe: Framework for Income Taxation (BEFIT), merits a thorough dialogue with all involved…

CFE Tax Advisers Europe · filed 21 Dec 2023 · source

Attached is CFE Tax Advisers Europe's Opinion Statement FC 10/2023 on the EU Commission Transfer Pricing Proposal. CFE welcomes the opportunity to contribute through ongoing engagement with the European Commission and European Parliament, in discussions in our role as a Member of the EU expert group, Platform for Tax Good Governance and Aggressive Tax Planning and via the public consultation process.

CFE Tax Advisers Europe · filed 21 Dec 2023 · source

Attached is CFE Tax Advisers Europe's Opinion Statement FC 9/2023 on the EU Commission Proposal on establishing a Head Office Tax system for micro, small and medium sized enterprises and amending Directive 2011/16/EU.

Deloitte · filed 3 Jan 2024 · source

We are pleased to respond on behalf of the Deloitte firms in Europe to the European Commission Public Consultation on the Proposal for a Council Directive on Transfer Pricing (the TP Proposal) presented on 12 September 2023 and welcome the opportunity for debate on this topic. This letter is submitted to provide background context and comments on the TP Proposal.

Deloitte · filed 24 Jan 2024 · source

We are pleased to respond on behalf of the Deloitte firms in Europe to the European Commission Public Consultation on the Proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT or the BEFIT Proposal or the Proposal) presented on 12 September 2023 and welcome the opportunity for debate on this topic.

CFE Tax Advisers Europe · filed 24 Jan 2024 · source

CFE welcomes the opportunity to contribute its input on the proposed Council Directive: Business in Europe: Framework for Income Taxation (BEFIT). The question that arises is whether there a need for BEFIT and is it in line with the stated legal bases of article 115 of the Treaty on Functioning of the European Union, its subsidiarity and its proportionality.

New EU system for the avoidance of double taxation in the field of withholding taxes

Deloitte · filed 18 Sept 2023 · source

We are pleased to respond on behalf of the Deloitte firms in the European Union to the European Commission Public Consultation on the Proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes (the FASTER Proposal) presented on 19 June 2023 and welcome the opportunity for debate on this topic. Please refer to our letter for further details and comments on the FASTER Proposal.

CFE Tax Advisers Europe · filed 18 Sept 2023 · source

CFE Tax Advisers Europe has now published an Opinion Statement concerning the EU Commissions withholding tax proposal to introduce legislation on a new EU system for the avoidance of double taxation and prevention of tax abuse: Faster and Safer Relief of Excess Withholding Taxes.

Debt equity bias reduction allowance (DEBRA)

Deloitte · filed 29 Jul 2022 · source

We are pleased to respond on behalf of the Deloitte firms in Europe to the European Commission Public Consultation on the Proposal published by the European Commission on 11 May 2022 for a Council Directive on laying down rules on a debt-equity bias reduction allowance and on limiting the deductibility of interest for corporate income tax purposes and welcome the opportunity for debate on this topic.

CFE Tax Advisers Europe · filed 29 Jul 2022 · source

CFE Tax Advisers Europe has issued an Opinion Statement on the European Commission Proposal for a Council Directive on debt-equity bias reduction allowance and on limiting the deductibility of interest for corporate income tax purposes (“DEBRA”).

EU rules on administrative cooperation - recast

CFE Tax Advisers Europe · filed 9 Feb 2026 · source

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.

Deloitte · filed 10 Feb 2026 · source

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.

Fighting the use of shell entities and arrangements for tax purposes

Deloitte · filed 6 Apr 2022 · source

We are pleased to respond on behalf of the Deloitte firms in the European Union to the European Commission Public Consultation on the Proposal published by the European Commission on 22 December 2021 for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU (the “Proposal”) and welcome the opportunity for debate on this topic.

CFE Tax Advisers Europe · filed 6 Apr 2022 · source

FE Tax Advisers Europe has issued an Opinion Statement on the EU proposal on fighting the use of shell entities and arrangements for tax purposes (Unshell or ATAD3 proposal). CFE Tax Advisers Europe welcomes the work of the European Commission in seeking to reduce tax evasion throughout the EU, the aim of which CFE has always fully supported.

Tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in the European Union

Deloitte · filed 12 Oct 2022 · source

We are pleased to respond on behalf of the Deloitte1 firms in Europe to the European Commission Public Consultation on the step up of the fight against tax evasion and “aggressive tax planning” by addressing the role of what the Commission designates as “enablers” who create complex and non-transparent structures, and welcome the opportunity for debate on this topic.

CFE Tax Advisers Europe · filed 12 Oct 2022 · source

CFE Tax Advisers Europe has issued an Opinion Statement on the public consultation launched by the European Commission on 6 July 2022 on the policy options being considered ‘to improve a regulatory framework for tax intermediaries', through a legislative proposal to tackle the role of ‘Enablers’ that facilitate tax evasion and aggressive tax planning in the European Union (Securing the Activity Framework of Enablers…

Minimum level of taxation for large multinational groups

Deloitte · filed 6 Apr 2022 · source

We are pleased to respond on behalf of the Deloitte firms in the European Union to the European Commission Public Consultation on the Proposal published by the European Commission on 22 December 2021 for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union (the “Proposal”) and welcome the opportunity for debate on this topic.

CFE Tax Advisers Europe · filed 6 Apr 2022 · source

CFE Tax Advisers Europe has issued an Opinion Statement on the ongoing process that seeks to enact the Pillar 2 political agreement into the legal order of the EU and other states. CFE welcomes the historic agreement on the global tax reform with a key objective of stabilising the international corporate tax framework arising from the challenges of the digitalising economy.

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