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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
CTA
CFE Tax Advisers Europe

Other · Belgium

12
files engaged
of 583 tracked
15
positions filed
in those 583 files
2
declared FTE
self-declared
2
EP accreditations
as declared to the register

Declared costs: €100K+ a year · in the register since 2008

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

CFE Tax Advisers Europe · filed 6 Apr 2022 · source

FE Tax Advisers Europe has issued an Opinion Statement on the EU proposal on fighting the use of shell entities and arrangements for tax purposes (Unshell or ATAD3 proposal). CFE Tax Advisers Europe welcomes the work of the European Commission in seeking to reduce tax evasion throughout the EU, the aim of which CFE has always fully supported.

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.

CFE Tax Advisers Europe · filed 6 Apr 2022 · source

CFE Tax Advisers Europe has issued an Opinion Statement on the ongoing process that seeks to enact the Pillar 2 political agreement into the legal order of the EU and other states. CFE welcomes the historic agreement on the global tax reform with a key objective of stabilising the international corporate tax framework arising from the challenges of the digitalising economy.

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