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.
Call for evidence on the functioning of the ATAD- Invest Europe Perspective
Positions & consultation responses
18 Sep 2024
Tax paid by multinationals – template and electronic formats for ‘Country-by-Country’ reports
Positions & consultation responses
05 Sep 2024
Invest Europe FASTER position paper
Positions & consultation responses
19 Sep 2023
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
Feedback to EC Roadmap on business taxation for the 21st century
Positions & consultation responses
01 Apr 2021
Position Paper on the Omnibus on taxation
Positions & consultation responses
30 Mar 2026
MEMBER ONLY
DAC 6 member guide
Member guides
25 Jun 2020
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
Response to the public consultation on an Evaluation of the Directives on Administrative Cooperation in the Field of Direct Taxation
Positions & consultation responses
30 Jul 2024
Invest Europe Answer to EC Consultation on SAFE
Positions & consultation responses
12 Oct 2022
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
Response to OECD Consultation on Treaty Entitlement of non-CIV Funds (BEPS Action Point 6)
Positions & consultation responses
22 Apr 2016
Observations on the EC consultation on taxation
Positions & consultation responses
19 Apr 2011