Invest Europe

Position Paper on possible recast of DAC6 and ATAD3

Positions & consultation responses

10 Feb 2026

Invest Europe welcomes the opportunity to contribute to the evaluation and recast of the DAC6 and the potential integration of the Unshell Directive (ATAD3) into a simplified framework. While recognising that DAC plays an important role in enhancing tax transparency and combating aggressive cross-border tax planning, Invest Europe highlights that the current application of DAC6 across Member States is fragmented and imposes disproportionate administrative burdens on intermediaries and investors.

Th Key Policy Areas