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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.

DFV
DIE FAMILIENUNTERNEHMER e.V.

Industry association · Germany

2
files engaged
of 583 tracked
2
positions filed
in those 583 files
1
declared FTE
self-declared
1
EP accreditations
as declared to the register

Declared costs: €100K+ a year · in the register since 2015

BUN
13
files engaged
of 583 tracked
16
positions filed
in those 583 files
3
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €200K+ a year · in the register since 2013

Files both filed on (2)

Rationalisation of reporting requirements · Debt equity bias reduction allowance (DEBRA)

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.

Rationalisation of reporting requirements

Bundessteuerberaterkammer · filed 28 Nov 2023 · source

The Federal Chamber of Tax Consultants is grateful for the opportunity to comment on the initiative to rationalise reporting obligations of 17 October 2023, which aims to reduce reporting obligations for businesses and administrations based on EU law. In its subsequent comments, the Federal Chamber of Tax Consultants makes specific proposals to reduce reporting obligations and avoid double reporting.

Filed in German · English published by the European Commission

DIE FAMILIENUNTERNEHMER e.V. · filed 30 Nov 2023 · source

Family entrepreneurs expressly welcome the Commission’s approach to reducing red tape in the field of documentary requirements. In view of the new obligations created in the current parliamentary term and the reporting obligations that have already been initiated and are being implemented, the requirement for a 25 % reduction is undoubtedly too small.

Filed in German · English published by the European Commission

Debt equity bias reduction allowance (DEBRA)

DIE FAMILIENUNTERNEHMER e.V. · filed 22 Jul 2022 · source

DIE FAMILIENUNTERNEHMER have for decades advocated an interest adjustment of the profit tax base with an indexed, increasing flat interest rate for the reasons mentioned above. In this respect, the initiative of the EU Commission presented in 2021 under the title DEBRA met with approval in principle from DIE FAMILIENUNTERNEHMER.

Bundessteuerberaterkammer · filed 29 Jul 2022 · source

Opinion of the Federal Chamber of Tax Advisors on the proposal for a Council Directive laying down rules on an allowance to reduce the tax advantage of debt over equity financing and to limit the deductibility of interest for corporate tax purposes.

Filed in German · English published by the European Commission

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