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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
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 · 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

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

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

Minimum level of taxation for large multinational groups

MEDEF · filed 31 Mar 2022 · source

The Mouvement des Entreprises de France supports the global minimum tax project, in that it can limit certain excessive tax differences between countries. However, this important political objective must not be achieved at the expense of European (including French) companies.

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.

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