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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.

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

Fighting the use of shell entities and arrangements for tax purposes · 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.

Fighting the use of shell entities and arrangements for tax purposes

Pirola Pennuto Zei & Associati · filed 6 Apr 2022 · source

We would like to thank the EU Commission for the opportunity to submit our comments on the Commision’s Proposal for a Council Directive laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU. In this respect, please find attached our observations

Bundessteuerberaterkammer · filed 6 Apr 2022 · source

The Federal Chamber of Tax Advisers (BStBK) represents the interests of more than 100 000 tax advisers in Germany vis-à-vis the Bundestag, the Bundesrat, the Federal Ministries, the heads of civil service, the courts and the institutions of the EU and the OECD.

Filed in German · English published by the European Commission

Minimum level of taxation for large multinational groups

Pirola Pennuto Zei & Associati · filed 6 Apr 2022 · source

We would like to thank the EU Commission for the opportunity to submit our comments on the Commission’s Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union. In this respect, please find attached our observations.

Bundessteuerberaterkammer · filed 6 Apr 2022 · source

The Federal Chamber of Tax Advisers (BStBK) represents the interests of more than 100 000 tax advisers in Germany vis-à-vis the Bundestag, the Bundesrat, the Federal Ministries, the heads of civil service, the courts and the institutions of the EU and the OECD.

Filed in German · English published by the European Commission

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