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.
Industry association · Sweden
Industry association · Germany
Declared costs: €300K+ a year · in the register since 2013
Commercial transactions: combating late payment · VAT in the Digital Age
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.
Swedish Federation of Business Owners · filed 15 Mar 2023 · source
The Swedish Federation of Business Owners (Swedish Federation of Business Owners) is co-founder of the Association for Effective Business Transactions (www.betaltider.se). In dialogue with the Swedish Government and a number of representatives from large companies, we have worked on various proposals and solutions to shorten payment times in Sweden.
Filed in Swedish · English published by the European Commission
Deutscher Steuerberaterverband e.V. · filed 9 Nov 2023 · source
In principle, the German Tax Consultants Association (DStV) welcomes the Commission’s proposal for a regulation on combating late payment in commercial transactions 2023/0323 (COD). EU small and medium-sized enterprises (SMEs), which rely on timely and predictable cash flows to improve liquidity planning, are particularly affected by the negative consequences of late payments in commercial transactions.
Filed in German · English published by the European Commission
Deutscher Steuerberaterverband e.V. · filed 5 May 2022 · source
The Deutsches Steuerberaterverband e.V. (DStV) represents some 36 500 professionals, representing more than 60 % of tax advisers, tax representatives, auditors, sworn accountants and professional companies in Germany. The DStV represents its interests in the professional law of tax advisors and accountants, tax law, accounting and auditing.
Filed in German · English published by the European Commission
Deutscher Steuerberaterverband e.V. · filed 3 Apr 2023 · source
Based on e-invoicing, more and more countries are transforming their traditional VAT compliance into a digital transfer of data with the tax authorities. This also applies to those Member States whose different systems cause fragmentation in the internal market and additional compliance costs for businesses operating cross-border. For this reason, the Deutscher Steuerberaterverband e.V.
Filed in German · English published by the European Commission
Swedish Federation of Business Owners · filed 4 Apr 2023 · source
The Federation of Swedish Business Owners (Företagarna) wishes to give the following feedback regarding the proposed Council regulation. We acknowledge the need for further harmonised rules regarding VAT in cross-border trade in the single market. The most central aspects of the sharing of information between member states' authorities are necessary to facilitiate simplified VAT handling.
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