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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.

STE
Steuerberater

Other · Germany

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

Files both filed on (2)

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.

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.

EU rules on administrative cooperation - recast

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

KPMG member firms in the EU · filed 10 Feb 2026 · source

KPMG member firms in the European Union are pleased to provide comments on the European Commissions public consultation "EU rules on administrative cooperation in the field of taxation recast". We welcome the European Commission's initiative to clarify, simplify and improve the functioning of EU rules on administrative cooperation in the field of taxation, with the aim of reducing the administrative burden for…

Tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in the European Union

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

KPMG member firms in the EU · filed 11 Oct 2022 · source

KPMG member firms in the EU are pleased to provide comments on the European Commission’s initiative for “Tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning”. Given that the call for evidence and the public consultation were published simultaneously, our comments - set out in the attached letter, aim to address the issues noted in the inception impact assessment as well as…

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