On 10 February 2026, the European Tax Adviser Federation (ETAF) submitted its feedback to the European Commission’s call for evidence and public consultation on a possible recast of the Directive on administrative cooperation in the field of taxation (DAC).
ETAF welcomes this step as a continuation of the Commission’s work following its evaluation of the DAC framework and as part of its wider objectives to simplify EU legislation and reduce reporting-related administrative burdens for businesses, particularly small and medium-sized enterprises (SMEs).
While ETAF recognises the importance of the DAC in facilitating cooperation between tax authorities and strengthening tax transparency, it recommends to entirely remove the DAC 6 reporting obligations. Overall, the Directive has been amended eight times since its entry into force almost 15 years ago (DAC2 to DAC9). While these developments have strengthened administrative cooperation, they have also resulted in an increasingly complex legislative structure. Against this background, ETAF highlights that the cumulative development of the DAC raises questions as to whether all existing reporting obligations are necessary, appropriate and proportionate.
Within this broader context, ETAF’s members continue to identify the most significant practical challenges for the tax profession as arising from the reporting obligations introduced by Directive (EU) 2018/822 on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). Additionally, the Commission’s recent evaluation of the DAC, together with other institutional findings identifying DAC6 as the most problematic element of the DAC framework, is drawn upon to substantiate ETAF’s assessment and the positions reflected in its feedback.
On this basis, ETAF’s feedback focuses predominantly on DAC6 reporting obligations.
