Compare organizations

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.

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.

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.

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.

The European Banking Federation (EBF) welcomes the opportunity to provide additional input on the Commissions proposal for Business in Europe: Framework for Income Taxation (BEFIT). EBF is supportive, in principle, of the idea of comprehensive and uniform European tax regulation, particularly one that aims to address cross-border obstacles in the corporate tax field.

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.

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.

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.

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.

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.

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…

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.

The European Banking Federation (EBF) fully supports the EU’s general policy objective to curtail fraudulent and tax abusive behaviour. However, this new anti-tax avoidance initiative raises some concerns, both conceptually and technically.

The European Banking Federation (EBF) believes that the Regulation on Markets in Crypto-assets (“MICA”) definitional framework should be used as the starting point for the extension of DAC 2 to crypto-assets. It should be mapped to the DAC 2 definitional framework. Using a uniform definitional framework will be a key factor in a successful application of DAC 2 reporting on crypto-assets.

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 8 December 2022 for a Council Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation (the DAC8 Proposal) and welcome the opportunity for debate on this topic.

The European Banking Federation (EBF) is in favour of a level playing field for all types of assets and financial service providers, including Crypto-Assets, however this should not unproportionally increase the compliance burden on financial institutions (FIs).