ETAF feedback on the HOT proposal

December 20, 2023

On 20 December 2023, ETAF replied to the European Commission's public consultation on the proposal for a directive establishing a Head Office Tax (HOT) system for micro, small and medium sized enterprises.

We recognized the potential of the HOT initiative, especially for SMEs that may be planning to expand across the borders and may have been held back by the perspective of high compliance costs. However, as it stands, we expressed some concerns about how the proposed HOT initiative would work in practice and the unintended effects it could generate.

ETAF is a registered organisation in the EU Transparency Register, with the register identification number 760084520382-92.

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