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.
As European Anti Poverty Network Nederland (EAPN NL) we urge you to bring the VAT down to 0% for biological vegetables. This has two reasons. Firstly this good and healthy food can also get available for low(er) incomes and secondly it will promote a change of agriculture. Than we want to use this opportunity also to aks you to start a change in taxes that brings profit for all.
The Deutsches Steuerberaterverband e.V. (DStV) represents some 36 500 professionals, representing more than 60 % of tax advisers, tax representatives, auditors, sworn accountants and professional companies in Germany. The DStV represents its interests in the professional law of tax advisors and accountants, tax law, accounting and auditing.
Filed in German · English published by the European Commission
Based on e-invoicing, more and more countries are transforming their traditional VAT compliance into a digital transfer of data with the tax authorities. This also applies to those Member States whose different systems cause fragmentation in the internal market and additional compliance costs for businesses operating cross-border. For this reason, the Deutscher Steuerberaterverband e.V.
Filed in German · English published by the European Commission
As EAPN Netherlands, we consider the prevention of tax fraud and tax avoidance to be very important. We therefore welcome the establishment of a special committee by the European Parliament. In addition to putting an end to various, often national, loopholes that allow circumvention, we see two important steps that need to be taken, in addition to this new regulation, which we welcome: 1.
Filed in Dutch · English published by the European Commission
The Deutsche Steuerberaterverband e.V. (DStV) — the Federation of Tax Consulting and Economic Auditing Professions — represents around 36.500 nationwide, i.e. more than 60 % of professionals working independently in its own law, a large number of whom are also accountants or certified accountants.
Filed in German · English published by the European Commission
The Deutscher Steuerberaterverband e.V. has doubts as to the legality of minimum EU penalties for certain infringements of the obligation to notify under DAC 6. The level of penalties in the proposal is also set at such a level that they are no longer minimum penalties but also maximum penalties. Intermediaries must be excluded from the scope of such sanctions.
Filed in German · English published by the European Commission
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