Invest Europe

Further thoughts on the review of DAC6

Positions & consultation responses

09 Jun 2025

This position paper is a follow-up to Invest Europe's response to the public consultation on the review of DAC 1-6 from August 2024. It offers a critical assessment of the EU Directive DAC6, which mandates disclosure of potentially aggressive cross-border tax arrangements. While supporting its transparency goals, the letter highlights the Directive's excessive compliance burdens, inconsistent interpretations across Member States, and limited practical effectiveness. It calls for targeted reforms—such as clearer guidance, refined hallmarks, harmonized implementation, and streamlined procedures—to make DAC6 more proportionate, effective, and aligned with broader EU competitiveness and tax simplification objectives.

Th Kpi C Taxation