Positions & consultation responses
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.
Joint industry letter on EC Initiative to fight the use of shell entities
Positions & consultation responses
29 Oct 2021
Feedback to EC Roadmap on Withholding taxes
Positions & consultation responses
26 Oct 2021
Response to European Commission Consultation on fighting the use of shell entities and arrangements for tax purposes
Positions & consultation responses
27 Aug 2021
Feedback to EC Roadmap on DEBRA
Positions & consultation responses
12 Jul 2021
Response to European Commission Consultation on VAT rules for financial services
Positions & consultation responses
03 May 2021
Response to European Commission Consultation on Digital Levy
Positions & consultation responses
12 Apr 2021
Invest Europe comments on Tax Competitiveness and Investment Growth
Positions & consultation responses
25 Apr 2025
Invest Europe Business in Europe: Framework for Income Taxation (BEFIT) position paper
Positions & consultation responses
22 Jan 2024
The road has been paved with good intentions; let's move forward… in the right direction.
Opinion
20 Oct 2021
Feedback to EC Roadmap on VAT and financial services
Positions & consultation responses
22 Nov 2020
Joint industry letter on DAC 6 deferral - consistent application - JUNE 2020
Positions & consultation responses
29 Jun 2020
Joint FS industry letter to the EC on DAC 6 deferral
Positions & consultation responses
24 Apr 2020
Invest Europe letter to EC on deferral of DAC 6 application deadline
Positions & consultation responses
31 Mar 2020
PAE-Invest Europe response to the OECD Pillar One consultation
Positions & consultation responses
11 Nov 2019
Joint Letter Invest Europe/AIC on OECD BEPS Action 6
Positions & consultation responses
03 Feb 2017