OpenLobby.EU
Explore

Confédération Fiscale Européenne

CFE

Confédération Fiscale Européenne (CFE Tax Advisers Europe) is an umbrella organisation representing 30 national tax institutes and chambers of tax advisers from 26 European countries (EU and non-EU).

Lobbying Activity

Meeting with Raluca Trasca (Head of Unit Taxation and Customs Union)

29 Oct 2025 · VAT policy

Response to VAT package on travel and tourism

16 Oct 2025

CFE Tax Advisers Europe welcomes the opportunity to respond to the European Commissions consultation on the VAT rules applicable to the travel and tourism sector, and in particular to the Tour Operators Margin Scheme (TOMS). CFE is of the view that TOMS, in its current form, no longer fulfils its original objectives of simplification and fair taxation. The scheme gives rise to significant legal uncertainty, undermines the principle of VAT neutrality, and creates serious challenges in its application, especially in relation to business-to-business (B2B) transactions. The divergent application of the rules across Member States has further exacerbated competitive distortions and administrative burdens. These difficulties in part arise from the need to distinguish between inhouse and bought in supplies and the treatment of transactions involving non-EU suppliers. Please find attached the Opinion Statement of CFE Tax Advisers Europe for our detailed comments concerning the consultation.
Read full response

Response to 28th regime – a single harmonized set of rules for innovative companies throughout the EU

30 Sept 2025

CFE Tax Advisers Europe welcomes the opportunity to respond to the European Commissions consultation the 28th Regime, an initiative announced by European Commission President Ursula von der Leyen. CFE strongly supports the objective of creating a simplified EU-wide entity structure to facilitate the expansion of start-ups and scale-ups. Past experience with European legal forms, particularly Societas Europaea (SE), indicate that a new structure can only succeed if it resolves the fundamental tax, administrative and compliance issues that continue to fragment the Internal Market. CFE recognises that this initiative builds on wider EU efforts to strengthen competitiveness, deepen the market integration and support Europes transition towards innovation-driven growth. The 28th Regime should focus on practical tax simplification and coordination, introduce measures such as a single tax filing interface, harmonised documentation, simplified transfer pricing and startup-friendly loss relief, ensure compatibility with State aid law to provide legal certainty, leverage on digitalisation to reduce administrative burdens; and strengthen investor confidence by offering a trusted and recognisable EU kitemark. If designed with these priorities, the 28th Regime could become a meaningful tool to support innovation, competitiveness and scale-up growth in the European Union. Please see the attached Opinion Statement of CFE Tax Advisers Europe for our further input on specific aspects of the consultation questionnaire. We remain at your disposal for any queries. CFE Tax Advisers Europe
Read full response

Meeting with Reinhard Biebel (Head of Unit Taxation and Customs Union)

18 Sept 2025 · International and EU Tax Developments

Meeting with Katarina Koszeghy (Cabinet of Commissioner Wopke Hoekstra)

23 Jul 2025 · Pillar 2 Directive

Response to Evaluation of the Anti-Avoidance Tax Directive (ATAD)

11 Sept 2024

CFE Tax Advisers Europe is pleased to contribute to the European Commission public consultation on the evaluation of the EUs EU Anti-Tax Avoidance Directive (ATAD) and invite you to read our Opinion Statement. CFEs comments do not relate to the Commissions focus on quantitative assessment of the effectiveness of the measures as a minimum standard for addressing aggressive tax planning, nor to aspects such as evaluation of budget revenue generated as a result of the measures or costs for the stakeholders concerned, in particular tax administrations and affected businesses, as we do not possess such evidence nor data. Furthermore, CFE notes the difficulty in assessing ATAD's effectiveness is partly due to delayed implementation in some Member states of the EU, the requirement for tax authorities to audit companies and apply ATAD provisions, and the lack of published decisions on ATAD application. CFE would like to highlight the following key points from its Opinion Statement: ATAD poses a significant compliance burden and implementation has resulted in increased complexity, particularly when layered on top of existing national rules. CFEs primary remark is the complexity of the EUs anti-avoidance rule framework is potentially hindering the EU's competitiveness and ease of doing business. CFE notes the urgent need to create a more coherent tax-avoidance rule structure and reduce complexity in EU tax rules. ATAD has been effective in establishing the EUs anti-avoidance system and changing mentality, however its implementation has led to increased administrative burdens for businesses. The lack of comprehensive data makes it challenging to fully assess ATAD's effectiveness. There is an urgent need to align ATAD with newer initiatives such as EUs Directive on Minimum Tax (Pillar Two) and create a more coherent structure for EU tax rules. CFE notes the need for further simplification, to improve on the clarity of concepts and the need to implement definitions. CFEs emphasises the need to "declutter" the EUs anti-avoidance legislation (ATAD and partly DAC6), especially for companies in scope of Pillar Two, to reduce complexity and potential redundancies or duplication in reporting requirements. We invite you to read our Opinion Statement, and remain available for any queries you may have.
Read full response

Response to Evaluation of Administrative Cooperation in Direct Taxation

18 Jul 2024

CFE Tax Advisers Europe has published an Opinion Statement concerning the EU Commission evaluation of the Directive on Administrative Cooperation in the field of taxation in The European Union Union (DAC Directive 2011/16/EU). The EU Directive on Administrative Cooperation in the field of taxation (2016/16/EU), DAC, is the key instrument of the European Union for exchange of tax-related information and cooperation among revenue administrations of Member states in the area of direct taxation. The overall objective is to provide tools to better fight tax evasion and fraud, and to contribute to better assessment and overview of arrangements that fall within scope of the directive through exchange of relevant information among tax administrations. CFEs comments focus on DAC6, the iteration of the Directive that introduces mandatory disclosure rules in the European Union. CFE Tax Advisers Europe participated in the European Commission high-level consultation in 2023 focusing on interviews with various stakeholders. This submission aims to reinforce the assessment provided to the European Commission, with an aim to simplify and unify the DAC directive, evaluate the compliance burden, and identify effective and ineffective aspects of DAC. We believe that the European Commission should use this opportunity to evaluate whether the rules are still fit for purpose and proportionate, and to explore policy options that could simplify the rules overall. Our overall aim is to support policy-makers in achieving the objectives above while ensuring that secondary EU law and reporting obligations are proportionate and do not over-burden businesses or advisers, thereby undermining the policy goals of such initiatives and ultimately the competitiveness and the resilience of the Single Market. CFE in its statement identifies issues and makes recommendations surrounding: General Simplification of the Directive & Recast of Consolidated Version; Transparency of Reporting; Pillar 2 Compatibility; Professional Privilege; Revision of Hallmarks Broad Hallmarks & Commercially Valid Transactions; Penalties; Taxpayers Rights Overall Balance of Rights and Obligations in the Single Market. We invite you to read the statement and remain available for any queries you may have.
Read full response

Response to Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

CFE welcomes the opportunity to contribute its input on the proposed Council Directive: Business in Europe: Framework for Income Taxation (BEFIT). The question that arises is whether there a need for BEFIT and is it in line with the stated legal bases of article 115 of the Treaty on Functioning of the European Union, its subsidiarity and its proportionality. The BEFIT proposal needs to be considered from the point of view of the EU requiring increased revenues. This initiative is not being requested by companies themselves, including MNE groups. According to the opinion of the European Commission, several advantages would be provided by this initiative for companies, such as: establishing a level playing field, enhancing legal certainty, reducing compliance costs, encouraging businesses to operate cross-border and, as a result, stimulating investment and growth in the Union. CFE remarks that insufficient attention has been paid to the unpredictable impact of BEFIT on public finances of the Member States and, whilst the objective of BEFIT is to decrease complexity, compliance costs and legal uncertainty, the opposite seems to be the case. CFE in this Statement sets out detailed remarks concerning the proposal, and reiterates comments made in our Opinion Statement of 26 January 2023. CFE would like to emphasise the most fundamental remarks which we believe need to be taken into account before this directive could be subject to a vote for adoption: - The legal basis of the BEFIT Directive is not in line with EU law and is disproportionate in certain aspects of the directive. The given explanations and formulations by the European Commission are not sufficient to satisfy the legal basis to demonstrate that the aims of the initiative cannot be sufficiently addressed by the Member States themselves. - The timing for the BEFIT proposal is not appropriate bearing in mind the implementation process of Pillar Two. The proposal needs further development to be in line with Pillar Two. The interaction of BEFIT and the minimum tax rules would increase complexity to an unprecedented level, which would result in significant compliance costs and potentially make the EU a less attractive place to do business. - Also, the timeframe for implementation is very short considering the impact on Member States and the enterprises involved. The directive outlines many legislative adjustments and needs to be more coherent in the broader perspective. - CFE is concerned the tax administrations of Member States are not able and capable (yet) to deliver all launched initiatives on time, choosing instead to opt for a standard implementation with reference to the guidelines, which ultimately creates legal uncertainty for the taxpayers and enterprises involved. - The administrative costs for affected enterprises should not be underestimated, bearing in mind the different tax filings in a year that would need to occur: Pillar Two, BEFIT and national filings. Also, knowing that this directive currently foresees a timeline of seven years after implementation, CFE urges the Commission to clarify up-front what the sustainable solutions will be, particularly given there is a risk that the temporary solution could become the permanent one, if BEFIT is adopted. - The BEFIT rules also contain a set of tax adjustments to the financial accounting statements with certain tax depreciation rules and raises timing and quantification issues. and to contribute to the reduction of administrative burdens, the adjustments should align as much as possible with the adjustments under the Pillar Two rules. One possible method of simplification would be to specify the use of IFRS as a starting point for everyone within BEFIT. CFE and its Member Organisations stand ready to assist the Commission in considering the issues raised in our Statement in the course of the policy dialogue and public consultation.
Read full response

Response to Business in Europe: Framework for Income Taxation (BEFIT)

21 Dec 2023

Attached is CFE Tax Advisers Europe's Opinion Statement FC 10/2023 on the EU Commission Transfer Pricing Proposal. CFE welcomes the opportunity to contribute through ongoing engagement with the European Commission and European Parliament, in discussions in our role as a Member of the EU expert group, Platform for Tax Good Governance and Aggressive Tax Planning and via the public consultation process. Given the degree of difficulty in finding a common ground concerning the reform of EU corporate taxation, our response does not necessarily represent the view of each and every Member Organisation of CFE, although reasonable efforts have been made to provide a coherent and representative view of European tax institutes and associations of tax advisers. CFE in its Opinion Statement recommends a number of factors to be taken into consideration by the European Commission. In particular CFE would note the following: - CFE supports simplification, but it is not in favour of parallel standards as proposed by the Transfer Pricing Directive. This directive makes legal relationships intra-EU versus non-EU more complicated. Furthermore, it would be extremely challenging to codify the ambulatory, dynamic and evolving OECD Guidelines in EU legislation that would need to be implemented in the different national legislations of the Member States. Therefore, CFE considers that the legal basis of the Transfer Pricing Directive is not in line with the EU law, is not in line with the subsidiarity principle, and is therefore disproportionate. CFE is of the view that the explanations and formulations given by the European Commission do not adequately satisfy the legal basis and do not demonstrate that the aims of the initiative cannot be sufficiently addressed by Member States themselves. This argument is apparent in several of the legal initiatives from the EU that have been rolled out at breakneck speed. - The timeframe outlined is very short given the impact on Member States and the enterprises involved. The directive introduces a lot of legislative adjustments and should be more coherent in its broader perspective. Furthermore, the administrations of Member States are not able and capable (yet) of implementing all launched initiatives on time, often choosing instead to opt for average implementations with reference to the guidelines, as is also the case regarding this directive, which in the end would create legal uncertainty (also in respect to their rights) for the taxpayers and enterprises involved. - The administrative costs for the enterprises involve should not be underestimated. CFE and its Member Organisations stand ready to assist the Commission in considering the issues above in the course of the policy dialogue and public consultation.
Read full response

Response to Business in Europe: Framework for Income Taxation (BEFIT)

21 Dec 2023

Attached is CFE Tax Advisers Europe's Opinion Statement FC 9/2023 on the EU Commission Proposal on establishing a Head Office Tax system for micro, small and medium sized enterprises and amending Directive 2011/16/EU. CFE welcomes the opportunity to contribute through ongoing engagement with the European Commission and European Parliament, in discussions in our role as a Member of the EU expert group, Platform for Tax Good Governance and Aggressive Tax Planning and via the public consultation process. Given the degree of difficulty in finding a common ground concerning the reform of EU corporate taxation, our response does not necessarily represent the view of each and every Member Organisation of CFE, although reasonable efforts have been made to provide a coherent and representative view of European tax institutes and associations of tax advisers. CFE in its Opinion Statement recommends a number of factors to be taken into consideration by the European Commission. CFE and its Member Organisations stand ready to assist the Commission in considering the issues above in the course of the policy dialogue and public consultation.
Read full response

Response to Business in Europe: Framework for Income Taxation (BEFIT)

26 Jan 2023

CFE Tax Advisers Europe has issued an Opinion Statement on the European Commission Public Consultation on the Introduction of a New Corporate Taxation System in Europe. The European Commissions plans to overhaul Europes business taxation rules by introducing a single corporate tax rulebook, known as the Business in Europe: Framework for Income Taxation (BEFIT), merits a thorough dialogue with all involved stakeholders and Member states. Given the degree of difficulty in finding a common ground concerning the reform of EU corporate taxation, our response does not necessarily represent the view of each and every Member Organisation of CFE, although reasonable efforts have been made to provide a coherent and representative view of European tax institutes and associations of tax advisers. CFE Tax Advisers Europe recommends that the following factors are taken into consideration by the European Commission: BEFIT would represent a fundamental shift in the corporate tax landscape, and CFE would encourage the European Commission to defer further consideration of BEFIT until the rules for the implementation of Pillar Two have had sufficient time to be operational in practice. Only then should the European Union proceed with a process to analyse whether BEFIT would provide a benefit to tax authorities and MNEs. The Commission should take into account the subsidiarity principle of EU law and conduct a thorough quantitative and qualitative assessment of the impact of investment and revenue for all Member states, including sustainable revenue for the EU budget. Taxpayers have invested heavily over the last number of years to ensure that they comply with OECD Transfer Pricing requirements. The European Commission has not provided a rationale for moving away from that approach. The system will not eliminate the Arms Length Principle (ALP) and transfer pricing as we know it; it will only apply within the EU for the companies coming within the ambit of the legislation. MNEs will still be subject to traditional transfer pricing rules outside of the EU. This will create a two-tier system, which will lead to increased complexity and compliance costs for companies and tax authorities. The proposed risk-based approach to transfer-pricing does not address these concerns, and instead focuses on one non-traditional transfer-pricing method, which might be controversial from the perspective of policy and practice. The BEFIT proposal envisages that tax authorities would operate two different tax systems in parallel, which would not meet the stated objective of administrative simplification. In addition to tax authorities, a two-tier system could increase the administrative burden for companies balancing on the application edge of the BEFIT rules i.e. if local non-BEFIT rules and BEFIT rules would deviate to a large extent, it would make moving from one system to another difficult for taxpayers (such as an SMEs). If BEFIT rules would be introduced, it would not be just a one-off transition from current system(s) to the new BEFIT era. Going forward there would be a number of taxpayers balancing between the two systems each year. If there is an objective to prevent certain companies from abusing the ALP and the transfer-pricing provisions, certain provisions must be included to deter MNEs from engaging in formula-factor manipulation. CFE and its Member Organisations stand ready to assist the Commission in considering the issues above in the course of the policy dialogue and public consultation. We invite you to read the statement and remain available for any queries you may have. Kind regards, The Office Team at CFE Tax Advisers Europe Avenue de Tervueren 188A B - 1150 Brussels T. +32 2 761 00 91 E. info@taxadviserseurope.org W. www.taxadviserseurope.org EU Transparency Register No. 3543183647-05
Read full response

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

29 Nov 2022 · Physical meeting - EU COM planned measures to address the role of enablers involved in facilitating tax evasion, tax fraud and tax avoidance (SAFE)

Response to Debt equity bias reduction allowance (DEBRA)

29 Jul 2022

CFE Tax Advisers Europe has issued an Opinion Statement on the European Commission Proposal for a Council Directive on debt-equity bias reduction allowance and on limiting the deductibility of interest for corporate income tax purposes (“DEBRA”). CFE Tax Advisers Europe welcomes the work of the European Commission in examining measures through which the Single Market will benefit from better investment and growth, including measures to support long-term and sustainable corporate financing On the overall policy objective of this directive, and the notion that tax rules are causing a bias among European companies to use debt rather than equity financing, CFE makes the following observations: For public companies, the true debt/equity position for economic and commercial purposes is driven by the consolidated position, whereas much of the analysis supporting proposals of this nature is based on the debt/equity position of individual countries, whereas the EU proposal if adopted would apply at the level of individual companies. Inter-company debt may be relevant to tax planning (and for that reason is subject in most countries to thin capitalisation and other anti-avoidance rules) but it is completely irrelevant to the true debt/equity position for economic and commercial purposes. Similarly for private companies, the true debt/equity position for economic and commercial purposes is dependent not only on the funding of the company but on the debt which the owning entities (individuals/ families) may have incurred personally to finance the business. Lenders may insist on this to get the added security of personal assets; and there may be tax aspects in national tax systems bearing on the taxation of the individuals as well as the company. For public companies, the accounting rules (under which debt costs are expensed against profit, and equity costs are generally not), and which operate globally, are likely to be much more influential in determining the debt equity ratio than national tax rules. There is no general deduction for equity costs in the US tax system any more than in most European countries. Companies in any event often have little or no choice as regards whether debt or equity is available in concrete situations such as financing acquisitions. Even if tax is a factor, one needs to consider the whole picture including on taxation of equity or debt returns to investors, in trying to design policy to impact the situation. CFE is of the view the proposal as designed might be detrimental to start-ups and pull equity finance away from them. Corporate entities being able to choose between debt and equity funding, would be incentive to choose more to use equity. It is noted that there is a shortage of equity capital in Europe, as compared to the US, to finance start-ups: if more of the available equity capital is taken by corporate entities/ established companies, there will be even less available for start-ups (introducing a tax incentive for the fund-raising company will do nothing to affect the supply of equity finance from investors). CFE believes the DEBRA initiative should go together with an initiative to incentivise individuals to invest more in equity in the EU and also to avoid double economic and juridical taxation on eg. dividends distributed from one member state to individuals residing in another member state. CFE also notes the increasing complexity in the area of EU corporate tax law, including potential overlap between the DEBRA proposals with existing provisions of the ATAD directives, as well as national thin capitalisation rules (“thin cap”). This could lead to further complexity if the interaction of existing measures is not evaluated thoroughly. In addition with the implementation of Pillar 2, the effective tax rates could be pushed further down by giving another allowance. We invite you to read the Opinion Statement and would welcome any feedback or queries.
Read full response

Response to Update of the Reform Recommendations for regulation in professional services

1 Apr 2021

CFE Tax Advisers Europe, the leading body representing European tax institutes and associations of tax advisers, notes the European Commission roadmap on reform of professional services of March 2021 and welcomes the opportunity to comment. We invite you to read our statement on the topic, and remain available for any queries.
Read full response

Response to Detailed measures for the Definitive VAT System

23 Aug 2018

Dear Sir/Madam, Please find attached the Opinion Statement of CFE Tax Advisers Europe concerning the proposal to amend Directive 2006/112/EC as regards the introduction of the detailed technical measures for the operation of the definitive VAT system for the taxation of trade between Member States. CFE Tax Advisers Europe welcomes certain aspects of the proposal, however is concerned with the potential consequences of many aspects of the proposals, in particular the practical implications of introducing “Certified Taxable Persons” and the potential impact of the proposed Directive on SMEs. CFE also has practical concerns in relation to call-off stock and chain transactions, reverse charge supplies, and the special schemes extending the one-stop account for VAT. Please see the attached Opinion Statement for our detailed views on these matters. We remain at your disposal for any queries you may have concerning our Opinion Statement. Kind regards, CFE Tax Advisers Europe www.taxadviserseurope.org info@taxadviserseurope.org
Read full response

Meeting with Stephen Quest (Director-General Taxation and Customs Union)

25 Jan 2016 · Working dinner