On 29 July 2024, ETAF participated in the European Commission's evaluation of the Directive on administrative cooperation in tax matters (DAC) and its successive amendments (from DAC2 to DAC6).
ETAF welcomes very much this evaluation as a first concrete action in the framework of the ongoing European Commission’s effort to rationalise EU reporting requirements.
In principle, ETAF views the DAC as an effective tool for enhancing cooperation among tax authorities ithe European Union and combating tax evasion. While we acknowledge that DAC Directives have significantly increased information exchange, we must also recognize that they have resulted in a substantial volume of data that tax administrations must now manage. It is questionable whether all the information requested by the successive DACs are really in use and of use for the tax authorities. Furthermore, more and more reporting obligations were shifted onto taxpayers.
Our members found that the main current problematic reporting requirement for the tax profession originates from the Directive (EU) 2018/822 regarding mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (DAC6). The co-existence of the country-by-country disclosure requirements foreseen in Directive (EU) 2016/881 (DAC4) and other EU Directives is also creating some double reporting issues.
Therefore, after some preliminary comments on the evaluation itself, our feedback focuses on DAC6 and DAC4 requirements.
