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
Industry association · Germany
Declared costs: €300K+ a year · in the register since 2013
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
Deutscher Steuerberaterverband e.V. · filed 10 Feb 2026 · source
The opinion of the German Association of Tax Consultants (Deutscher Steuerberaterverband e.V. – DStV) is attached in DE/EN version: Summarising: The DStV reiterates its criticism of the DAC 6 reporting requirements. These have not produced the desired results, are not suitable for achieving the objectives and are disproportionate.
Filed in German · English published by the European Commission
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
Deutscher Steuerberaterverband e.V. · filed 7 Oct 2022 · source
The EU SAFE initiative aims to combat the role of ‘intermediators’ in designing, marketing or supporting tax evasion and aggressive tax planning, in particular by preventing ‘intermediators’ from setting up complex structures in third countries. Tax evasion, aggressive tax avoidance and money laundering remain serious problems for the Member States of the European Union.
Filed in German · English published by the European Commission
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