Side by side
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.
Other · Germany
Other · Belgium
Declared costs: €100K+ a year · in the register since 2008
EU rules on administrative cooperation - recast · Tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in the European Union
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
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.
Steuerberater · filed 18 Dec 2025 · source
The data to be reported for the different DAC reports shall be limited to what is necessary and a fully automated digital process shall be established between all European and national authorities involved across the EU. The reported data must also be analysed.
Filed in German · English published by the European Commission
CFE Tax Advisers Europe · filed 9 Feb 2026 · source
This contribution is submitted by CFE Tax Advisers Europe in response to the European Commissions public consultation and Call for Evidence on the recast of the Directive on Administrative Cooperation in the field of taxation (DAC). The submission sets out CFEs views, technical observations and recommendations based on practical experience with the application of the DAC framework across Member States.
Steuerberater · filed 9 Aug 2022 · source
—Action against aggressive tax planning yes, but with caution; we do not need any further rules that make planning advice more complicated; our profession does not only live from declaratory activities — Please not create more bureaucracy; the profession is becoming even more unattractive
Filed in German · English published by the European Commission
CFE Tax Advisers Europe · filed 12 Oct 2022 · source
CFE Tax Advisers Europe has issued an Opinion Statement on the public consultation launched by the European Commission on 6 July 2022 on the policy options being considered ‘to improve a regulatory framework for tax intermediaries', through a legislative proposal to tackle the role of ‘Enablers’ that facilitate tax evasion and aggressive tax planning in the European Union (Securing the Activity Framework of Enablers…
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