On 11 October 2022, ETAF replied to the European Commission's public consultation on a proposal for a Directive to tackle the role of enablers that facilitate tax evasion and aggressive tax planning (Securing the Activity Framework for Enablers – SAFE).
Our core messages are the following:
- Before releasing new measures, existing regulation should be thoroughly evaluated first.
- Regulated tax professionals are not “enablers”; they are rather “preventers” of aggressive tax planning.
- Regulated tax professionals have to be excluded from the scope of SAFE.
- To tackle the core of the problem, the material scope must stay limited to complex structures in non-EU countries.
- Clear definition of aggressive tax planning is crucial for the daily work of tax professionals.
- An EU register would only make sense for non-regulated tax professionals
