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.
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.
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 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…
—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 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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