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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.

FIR
4
files engaged
of 583 tracked
4
positions filed
in those 583 files
declared FTE
self-declared
EP accreditations
as declared to the register
MED
MEDEF

Industry association · France

44
files engaged
of 583 tracked
50
positions filed
in those 583 files
6.2
declared FTE
self-declared
4
EP accreditations
as declared to the register

Declared costs: €900K+ a year · in the register since 2009

Files both filed on (2)

Fighting the use of shell entities and arrangements for tax purposes · Financial services contracts concluded at a distance

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.

Fighting the use of shell entities and arrangements for tax purposes

Federazione Italiana Ristorazione · filed 7 Jun 2021 · source

Tax avoidance is the conduct put into practice by the taxpayer that engages in a legal transaction or a chain of legal acts which are lawful in themselves, with the sole aim of reducing the tax liability. With a few more precise examples of the situation in Italy For example, if the tax rates on the sale of immovable property are 35 % and the rate on the sale of shares is 20 %, the owner of the property can transfer…

Filed in Italian · English published by the European Commission

MEDEF · filed 17 Jun 2021 · source

In its Inception impact assessment, the European Commission indicates that the issue at stake is the use of legal entities with no or minimum substance and no real economic activities, by taxpayers operating cross-border to reduce their tax liability.

MEDEF · filed 4 Apr 2022 · source

Dear Sir/Madam, We thank you for the opportunity to participate in the public consultation on the proposal for a directive on “shell companies” and would like to share with you the following detailed comments and proposed amendments (please see attached). As always, we stand ready to further discuss and explain our views. Yours sincerely, [name removed] – MEDEF

Financial services contracts concluded at a distance

Federazione Italiana Ristorazione · filed 24 Jun 2021 · source

Despite the fact that the initiative tends to increase the possibility for consumers to buy, account must be taken of principles which, through an unmanaged policy, lead to real harm to the consumer. To date, a cellular phone has everyone and on some occasions even more than one.

Filed in Italian · English published by the European Commission

MEDEF · filed 8 Jul 2022 · source

The Mouvement des Entreprises de France (MEDEF) is the leading network of entrepreneurs in France, representing more than 173 000 member companies covering all sectors of activity, 95 % of which are SMEs/ETI. The mission of the French Business Movement is to promote and represent the interests of French companies vis-à-vis the French and European public authorities and to develop entrepreneurship.

Filed in French · English published by the European Commission

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