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 2016
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
European Tax Adviser Federation (ETAF) · filed 10 Feb 2026 · source
ETAF welcomes the DAC recast as a continuation of the Commissions work following its evaluation of the DAC framework and as part of its wider objectives to simplify EU legislation and reduce reporting-related administrative burdens for businesses, particularly small and medium-sized enterprises (SMEs).
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
European Tax Adviser Federation (ETAF) · filed 11 Oct 2022 · source
The European Tax Adviser Federation (ETAF) would like to thank the Commission for the opportunity to comment on its planned proposal for a Council Directive to tackle the role of enablers that facilitate tax evasion and aggressive tax planning. Please find attached our position paper. ETAF core messages are the following: 1. Before releasing new measures, existing regulation should be thoroughly evaluated first. 2.
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