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European Tax Adviser Federation

ETAF

The European Tax Adviser Federation represents tax practitioners at EU level, promoting good tax legislation and professional standards.

Lobbying Activity

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

4 Nov 2025 · Meeting regarding the composition of the VAT Expert Group

Tax advisers urge EU to open 28th regime to all

30 Sept 2025
Topic — A proposal for a harmonized EU corporate legal framework for innovative companies.
Message — ETAF demands the regime be optional and open to all companies to avoid market distortion. They advocate for a European Business Code to harmonize laws instead of creating parallel complexities.12
Why — The additional complexity of dual legal systems ensures a sustained need for professional tax advice.3
Impact — Traditional firms lose out if regulatory benefits are restricted to a vague category of innovative firms.4
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European Tax Adviser Federation urges broader confidentiality and deregulation

17 Sept 2025
Topic — European Commission evaluation of rules protecting whistleblowers reporting law breaches.
Message — ETAF requests a uniform definition of professional privilege to include tax advisers. They also propose doubling the employee threshold for mandatory internal reporting channels.12
Why — Expanding exemptions would protect their professional secrecy and reduce administrative costs.34
Impact — Employees in mid-sized firms would lose mandatory access to internal reporting channels.5
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ETAF urges tax exemptions to boost EU retail investment

4 Jul 2025
Topic — The initiative creates a European blueprint for harmonized savings and investment.
Message — ETAF supports non-binding recommendations to maintain national fiscal sovereignty. They advocate for EU-wide tax exemptions and common account naming. They also propose a single capital gains tax rate.123
Why — Digital interfaces would simplify reporting and reduce compliance burdens for advisors.4
Impact — Individual investors must bear all default risks without state-backed protections.5
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Tax advisers urge EU to protect professional standards

30 Jan 2025
Topic — The consultation seeks input on removing regulatory barriers to boost EU productivity.
Message — ETAF demands a dedicated regulation to simplify the complex European tax system. They argue that formal recognition of professional qualifications must remain mandatory. They advocate for a cooperative approach rather than Commission-led notification procedures.123
Why — This approach preserves the market position of established professionals by preventing deregulation.4
Impact — Foreign professionals face continued hurdles due to the refusal to waive qualifications.56
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

15 Jan 2025 · Tax policy

Meeting with Pasquale Tridico (Member of the European Parliament, Committee chair)

3 Oct 2024 · Meeting with Marion Fontana - European Tax Adviser Federation AISBL – ETAF

Meeting with Enikő Győri (Member of the European Parliament)

25 Sept 2024 · exchange of views on taxation

ETAF urges EU to reduce tax reporting duplication

10 Sept 2024
Topic — The European Commission is evaluating the Anti-Tax Avoidance Directive's effectiveness and implementation.
Message — The federation requests that the Commission simplify rules and reduce Member State options to minimize bureaucracy. They specifically propose waiving certain reporting for large multinational companies to avoid duplication with the new Minimum Tax Directive.12
Why — This would decrease administrative burdens and prevent the double taxation caused by overlapping regulations.3
Impact — National tax authorities might lose local control and flexibility in implementing specific anti-abuse measures.4
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Response to Evaluation of Administrative Cooperation in Direct Taxation

29 Jul 2024

Please find attached a statement from the European Tax Adviser Federation (ETAF) on the evaluation of the Directive on administrative cooperation in tax matters (DAC).
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

Please find attached the feedback from the European Tax Adviser Federation (ETAF) on the Business in Europe: Framework for Income Taxation (BEFIT) proposal.
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

20 Dec 2023

Please find attached the feedback of the European Tax Adviser Federation (ETAF) on the proposal for a Directive on Transfer Pricing.
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

20 Dec 2023

Please find attached the feedback of the European Tax Adviser Federation (ETAF) on a Proposal for a Directive establishing a Head Office Tax (HOT) system for micro, small and medium sized enterprises.
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ETAF urges EU to simplify burdensome tax reporting requirements

27 Nov 2023
Topic — EU initiative to reduce company reporting burdens by twenty-five percent across sectors.
Message — The federation requests making the rationalisation of EU reporting requirements a permanent exercise. They propose creating a white list of harmless arrangements to simplify tax disclosure rules. They recommend waiving specific anti-tax avoidance requirements for companies meeting new minimum tax thresholds.123
Why — Streamlining these rules would lower compliance costs and training burdens for tax practitioners.45
Impact — Tax authorities may lose early visibility on some cross-border financial arrangements.6
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Response to Communication on maximising the potential of talent mobility as part of the European Year of Skills

12 Oct 2023

The European Tax Adviser Federation (ETAF), which represents 215 000 regulated tax professionals, would like to thank the European Commission for the opportunity to comment on its upcoming recommendation on the recognition of qualifications of third country nationals. As preliminary remarks, ETAF would like to acknowledge the potential of this initiative to address labour and skills shortages in general, even if, in the tax area, there is only limited room for improvement because of the differences in tax laws, which constitute a de facto barrier to professional mobility. Please find attached a statement outlining some specificities of the regulated tax profession to be taken into account in the context of the discussion on the recognition of qualifications of third country nationals. Our comments relate to the scope of the initiative, the proposed alignment with Directive 2005/36/EC and the recognition of skills acquired in different contexts.
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European tax advisers urge mandatory relief at source system

18 Sept 2023
Topic — The consultation is about introducing a common EU system for withholding tax relief.
Message — The federation advocates for a mandatory relief at source system and expanding the rules to cover all payments subject to withholding taxes.12
Why — This would lower administrative burdens and compliance costs for tax professionals and investors.34
Impact — Investors face potential financial harm if intermediaries charge high fees for fast-track services.5
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Response to VAT in the Digital Age

4 Apr 2023

Please find attached the feedback of the European Tax Adviser Federation (ETAF) on the VAT in the digital age package (ViDA).
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Response to Strengthening existing rules and expanding exchange of information framework in the field of taxation (DAC8)

30 Mar 2023

Please find attached the feedback of the European Tax Adviser Federation (ETAF) on the proposal for an eighth amendment to the Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC8).
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Tax advisers urge caution on new EU corporate tax system

24 Jan 2023
Topic — This consultation addresses a proposal for a unified EU-wide corporate tax system.
Message — ETAF recommends requiring only the largest groups to use the new tax system. They suggest waiting for lessons from other global tax reforms before finalising rules.12
Why — Limiting the rules to large firms avoids high costs for smaller businesses.3
Impact — Corporate groups using non-EU accounting standards may face significantly higher tax burdens.4
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Tax Adviser Federation demands exclusion from new EU tax rules

11 Oct 2022
Topic — EU consultation on regulating intermediaries that facilitate tax evasion and aggressive tax planning.
Message — The federation demands that qualified tax professionals be exempt from the new rules. They request that the legislation focus only on tax structures outside Europe.12
Why — This would allow their members to avoid new compliance costs and professional oversight.34
Impact — Unregulated tax consultants would face stricter scrutiny and new registration requirements.56
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ETAF warns DEBRA interest limits could harm small businesses

27 Jul 2022
Topic — A proposal to reduce tax bias favoring debt over equity financing.
Message — ETAF requests exemptions for smaller companies and flexibility to prove reasons for business decisions. They also question the necessity of harmonizing interest deduction rules at the EU level.12
Why — Their clients would avoid tax increases and enjoy more flexible rules for business restructurings.3
Impact — Small firms lose because they cannot easily access equity markets to replace debt financing.4
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European Tax Advisers Urge Lower Burden in Shell Company Crackdown

6 Apr 2022
Topic — The European Commission proposal to prevent the misuse of shell entities for tax avoidance purposes.
Message — The organization calls for a simplified single set of indicators to reduce complexity and administrative costs. They suggest that the presumption of substance should remain valid until a substantial change occurs, rather than requiring annual proof.12
Why — These changes would reduce the workload and compliance costs for tax advisers and their clients.3
Impact — Tax authorities may find it harder to monitor and identify shell entities without annual reporting updates.4
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European tax advisers urge alignment with OECD minimum tax rules

18 Mar 2022
Topic — The implementation of a global minimum tax rate for large multinational enterprises.
Message — The federation requests that the EU strictly follow the OECD model rules and incorporate detailed implementation guidelines directly into the Directive. They also support a one-year extension of the application deadline to ensure a reasonable compromise for tax authorities and advisers.123
Why — This would ensure legal certainty and reduce the administrative burden on tax advisers and their clients.4
Impact — EU businesses could face a competitive disadvantage if international partners fail to adopt similar minimum taxation rules.5
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Response to EU Anti-money laundering supervisor

25 Nov 2021

The European Tax Adviser Federation (ETAF) is a European umbrella organisation for 280,000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. The main role and mission of ETAF is to represent the regulated tax profession at European level in liaising closely with European policy makers in order to promote good legislation in tax and professional matters. Please find attached ETAF position paper on the AML/CFT package.
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Response to New EU system for the avoidance of double taxation in the field of withholding taxes

26 Oct 2021

The European Tax Adviser Federation (ETAF) welcomes the European Commission’s intention to present, by the end of 2022, a proposal to establish a European withholding tax framework on dividend or interest payments. In principle, ETAF acknowledges that withholding taxes as such can reduce the risk of tax evasion and avoidance. On the other hand, though, under the current rules, investors face many hurdles and efforts in order to reach a taxation of their investment at the source which is in line with the respective double taxation agreement. Furthermore, refund procedures are often complex, lengthy and costly and can even more discourage investors from making investments in certain countries or having to accept double taxation, which can not be the intention of the Single Market. ETAF believes that establishing a fully-fledged common EU relief at source system (option 2) would be valuable as long as it stays as simple as possible. Concerning option 3, we don’t see how a mandatory exchange of beneficial owner-related information on an automated basis alone would meet the purpose of preventing tax avoidance and double taxation.
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Response to Business taxation for the 21st century

1 Apr 2021

The European Tax Adviser Federation, ETAF, is a European umbrella organisation for more than 300.000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. ETAF thanks the Commission for the opportunity to comment on the above-mentioned roadmap. ETAF welcomes the attention of the European Commission to the stability of EU Member States’ public revenues. ETAF supports the effort of the Commission to tackle the topic of business taxation by setting principles and priorities for the medium/long term. ETAF believes that the stabilisation of public revenues should be tackled by supporting the European economy to thrive again. Please find attached the comments of ETAF on the European Commission’s Roadmap for a Communication on business taxation for the 21st century.
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Response to Update of the Reform Recommendations for regulation in professional services

1 Apr 2021

The European Tax Adviser Federation (ETAF) is the European umbrella organization for 280,000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. Our main role is to represent the tax profession at European level in order to promote good legislation in tax and professional matters while contributing to the fight against tax abuse. We defend the independence and confidentiality of tax practitioners and advocate for a strong professional regulation which contributes to the safety and protection of consumers. Tax advisers are partners and service providers for the economy and contribute significantly to positive economic development with their competent advice. Our profession fully supports the further deepening of the internal market. The single market has been – and still is – a great example of success. It has made a decisive contribution to the progress of the economy and opened up new market opportunities for medium-sized companies. The 2017 Commission communication and the current roadmap entail several statements which – in our view – do not reflect adequately what professional regulation stands for. ETAF would like to briefly elaborate on the specific requirements the Commission mentions in its Roadmap and explain, why these requirements are not at all a barrier, but rather an indispensable safety-net for consumers. First of all, it should be noted that the statement regarding the “unaddressed reforms” on page 1, meaning that certain Member States did not implement its recommendations, does not apply in any way to the profession of tax advisers. On the contrary, we are aware that several countries – which are members of ETAF – have done a huge effort to adapt its legislation to the Commissions’ recommendations. For example, in Germany, the profession has adapted its minimum fees to EU law, fully implemented the provisions of judgment C-342/14 (X-Steuerberatungsgesellschaft), enabled partial access as part of the implementation of the Qualification Directive and reformed its ownership structure. Likewise, Belgium has also amended its regulation and made it compliant with EU Law. Following a judgment of the European Court of Justice (Commission v. Belgium C 348/18), the incompatibility rules prohibiting the simultaneous exercise of any other economic activity for all types of accountancy professions have been re-assessed. Nowadays, it is indeed possible to exercise two activities simultaneously, if you ask for permission and there is no conflict of interests between both activities. These examples show that there is no lack of willingness from Member States to reform their professional regulations – where appropriate –, and that the profession is committed and ready to do compromises when it comes to contribute to the further deepening of the Single Market. However, not at any cost. There are certain requirements that cannot and should not be amended because they aim to protect the general interest. See attachment.
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Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

9 Mar 2021 · digital taxation

Response to Taxpayers’ Rights in the Single Market (Recommendation)

27 Nov 2020

The European Tax Adviser Federation, ETAF, is a European umbrella organization for more than 280.000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. ETAF thanks the Commission for the opportunity to comment on its Roadmap on a Communication and a Recommendation on “Taxpayers’ rights in the Single Market”. ETAF supports the project of the European Commission to promote taxpayers’ rights in the Single Market by issuing a Communication and a Recommendation to the EU Member States. We believe that these measures can be a first step to encourage the Member States to seriously consider the rights of taxpayers whenever issuing new tax laws. A strengthened relationship between the tax administration and the taxpayers relying more on cooperation than on confrontation is indeed desirable. Such an initiative is even more relevant during a time when many EU Member States are working on tax initiatives that have an impact on small/micro businesses and individual taxpayers are deploying their economic activity in more than one country. To prevent these initiatives from adding complexity for the economic operators, it is key that EU Member States agree on some basic guidelines to improve the relationship between tax authorities and taxpayers which could strengthen tax compliance. However, ETAF stresses the need for the European Commission to openly recognize the essential contribution of regulated tax advisers in this context. Of course, an improvement of the relationship between the taxpayers and the tax administration will be desirable, but this relationship will – very naturally – never be free of confrontation or legal disputes. And here, a highly qualified, independent and regulated tax adviser plays an important bridging function at the interface between the taxpayer and the Member State – provided that a binding professional law obliges the tax adviser him- or herself to act in full compliance with the tax laws. At the same time, a regulated tax adviser will always keep a close eye to work in the very best interest of the taxpayer. Even small and micro-businesses very often make use of a tax adviser in order to have this burden off, and to concentrate on their core business. Therefore, ETAF encourages the European Commission to consider and to strengthen the key role of regulated tax advisers. Otherwise, the initiative, which is in itself to be welcomed, might risk to be unilateral and to lack integrity, if it focuses only on the taxpayer’s rights. ETAF believes that the objectives of the Communication and Recommendation on taxpayers’ rights should be: - Improving the relationship between taxpayers and tax administrations; - Increasing the tax morale of the citizens - Enhancing efficiency and effectiveness of a tax system ETAF supports a Communication and Recommendation that include: - Core principles about rights and obligations governing the relationship between tax authorities and taxpayers; - An enhanced cooperation, trust and confidence between tax authorities and taxpayers. On the one side, this means cooperative compliance by taxpayers, on the other side it means respecting the privacy of certain sensitive taxpayers’ information by tax authorities. - Striking a balance between the need for tax law / tax procedures to be enforced (taxpayers to correctly file their tax return, provide complete info to tax authorities) and the rights of taxpayers to be respected (legal certainty, transparent treatment by tax authorities, presumption of honesty). - An acknowledgment of the work of tax advisers in strengthening the collaboration between taxpayers and tax authorities and of the confidentiality principle which forms the basis of a trusted relationship between taxpayers and tax advisers. - Encouraging EU Member States and their respective tax administrations to use technological developments in a coordinate way at EU level and in a cooperative way with taxpayers.
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Response to Taxpayers’ Rights in the Single Market (communication)

27 Nov 2020

The European Tax Adviser Federation, ETAF, is a European umbrella organization for more than 280.000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. ETAF thanks the Commission for the opportunity to comment on its Roadmap on a Communication and a Recommendation on “Taxpayers’ rights in the Single Market”. ETAF supports the project of the European Commission to promote taxpayers’ rights in the Single Market by issuing a Communication and a Recommendation to the EU Member States. We believe that these measures can be a first step to encourage the Member States to seriously consider the rights of taxpayers whenever issuing new tax laws. A strengthened relationship between the tax administration and the taxpayers relying more on cooperation than on confrontation is indeed desirable. Such an initiative is even more relevant during a time when many EU Member States are working on tax initiatives that have an impact on small/micro businesses and individual taxpayers are deploying their economic activity in more than one country. To prevent these initiatives from adding complexity for the economic operators, it is key that EU Member States agree on some basic guidelines to improve the relationship between tax authorities and taxpayers which could strengthen tax compliance. However, ETAF stresses the need for the European Commission to openly recognize the essential contribution of regulated tax advisers in this context. Of course, an improvement of the relationship between the taxpayers and the tax administration will be desirable, but this relationship will – very naturally – never be free of confrontation or legal disputes. And here, a highly qualified, independent and regulated tax adviser plays an important bridging function at the interface between the taxpayer and the Member State – provided that a binding professional law obliges the tax adviser him- or herself to act in full compliance with the tax laws. At the same time, a regulated tax adviser will always keep a close eye to work in the very best interest of the taxpayer. Even small and micro-businesses very often make use of a tax adviser in order to have this burden off, and to concentrate on their core business. Therefore, ETAF encourages the European Commission to consider and to strengthen the key role of regulated tax advisers. Otherwise, the initiative, which is in itself to be welcomed, might risk to be unilateral and to lack integrity, if it focuses only on the taxpayer’s rights. ETAF believes that the objectives of the Communication and Recommendation on taxpayers’ rights should be: - Improving the relationship between taxpayers and tax administrations; - Increasing the tax morale of the citizens - Enhancing efficiency and effectiveness of a tax system ETAF supports a Communication and Recommendation that include: - Core principles about rights and obligations governing the relationship between tax authorities and taxpayers; - An enhanced cooperation, trust and confidence between tax authorities and taxpayers. On the one side, this means cooperative compliance by taxpayers, on the other side it means respecting the privacy of certain sensitive taxpayers’ information by tax authorities. - Striking a balance between the need for tax law / tax procedures to be enforced (taxpayers to correctly file their tax return, provide complete info to tax authorities) and the rights of taxpayers to be respected (legal certainty, transparent treatment by tax authorities, presumption of honesty). - An acknowledgment of the work of tax advisers in strengthening the collaboration between taxpayers and tax authorities and of the confidentiality principle which forms the basis of a trusted relationship between taxpayers and tax advisers. - Encouraging EU Member States and their respective tax administrations to use technological developments in a coordinate way at EU level and in a cooperative way with taxpayers.
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Response to Review of the VAT rules for financial and insurance services

18 Nov 2020

The European Tax Adviser Federation, ETAF, is a European umbrella organisation for more than 280.000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. ETAF thanks the Commission for the opportunity to comment on its Roadmap / Inception impact assessment on the “Review of the VAT rules for financial and insurance services”. It is worth reminding that VAT on Financial and insurance services is regulated by the VAT Directive (Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax). Article 1 of the VAT Directive introduces a definition of VAT as a “general tax on consumption [of goods and services] exactly proportional to the price of the goods and services”. However, article 135 of the VAT Directive requires EU Member States to adopt VAT legislation that exempts supplies of specified financial services. By means of the initiative under consideration, the European Commission has the objective of reviewing the rules of the VAT Directive on financial and insurance services. In particular, the Roadmap seeks to review the exemption currently in place by either (i) removing the exemption or (ii) modifying the scope through taxing some type of services. Feedback The European Tax Adviser Federation ETAF supports the project of the European Commission of modernizing the VAT Directive in order to reduce the complexities and costs for economic operators active in the financial and insurance sector. The general exemption included in the VAT Directive on financial and insurance services implies that on one hand no tax is applied to the financial and insurance services identified by the Directive, but on the other hand no deduction of input VAT is allowed for the VAT paid on goods or services acquired by the services provider of those activities. Therefore, ETAF recognizes the possible negative impacts of the exemption on the economic operators active in the financial and insurance sectors. However, given the peculiarity and sensitivity of the financial and insurance market, ETAF believes that the players active in this field and the EU Member States should be directly and primarily involved in the process of amending the VAT Directive.
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Response to Conferring implementing powers on the Commission in the area of value added tax

29 Oct 2020

The European Tax Adviser Federation welcomes the project of the European Commission to turn the VAT Committee into a “comitology committee” that would oversee the adoption of implementing acts by the Commission. In particular, ETAF recognizes that conferring additional implementing powers to the Commission in the area of VAT might have a positive impact in terms of harmonization of technical measures that are otherwise implemented heterogeneously at national level. Since the Comitology procedure includes the supervision of national experts within the comitology committee that would vote on the implementing acts proposed by the Commission, ETAF believes that the national sovereignty of the Member States would not be compromised. Quite the opposite, a comitology committee on VAT means that national experts of the Member States would have the possibility to discuss and approve VAT implementing measures for the benefit of their respective countries and the EU as a whole. A way to simplify the decision-making process ETAF believes that by turning the VAT Committee into a comitology committee, the implementing measures proposed by the European Commission would be more harmonized and coherent. That is so because the representatives of the Member States in this new and empowered “VAT Committee” would have the responsibility to agree on technical VAT measures that have a direct implementation at national level. The possibility to provide the European Commission with implementing powers has another advantage, namely avoiding infringement procedures against Member States. Infringement procedures are very heavy and time-consuming due to all the steps and time constraints they entail (letter of formal notice, reasoned opinion, referral to the Court, etc.) and it can take years to have a tangible solution. Therefore, it would be much more efficient to confer the Commission with implementing powers beforehand by changing the status of the VAT Committee to a comitology committee and thus be able to speed things up and guarantee a harmonized implementation of EU legislation a priori. As practitioners who work on a daily basis with the provisions of the VAT Directive, it is in our interest to have a uniform and harmonized interpretation thereof. Thus, we can be certain that the way of understanding and implementing the rules within the Member State we operate is correct. Clarity on the interpretation and application of these rules among Member States is a great advantage for taxpayers, tax administrations and tax advisers. How to keep the balance between the Commission and the Member States The system set by the Comitology Regulation (Regulation (EU) No 182/2011) ensures that the implementing measures proposed by the Commission are only adopted if a large majority of representatives of the Member States is in favor. Therefore, this system would balance the stronger implementing power of the Commission while ensuring a democratic control by EU Member States. The possible active role of the VAT Expert Group ETAF believes that the impact of the implementing acts on taxpayers could be better addressed by the Commission. ETAF suggests to introduce an advisory role of the VAT Expert Group within this process. As it stands today, the VAT Expert Group includes representatives of businesses, professionals and academics who assist and advise the European Commission on VAT matters by bringing the point of view of the real economic system. ETAF believes that the provision of non-binding opinions by the VAT Expert Group on the implementing measures to be proposed by the Commission to the VAT Committee would help the VAT Committee itself in estimating the real effects of such measures on the day-to-day activity of the economic operators that would have to comply with them. Additional info on the ETAF feedback can be found in the attached document.
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Response to Action Plan on fight against tax fraud

1 Apr 2020

The European Tax Adviser Federation, ETAF, is a European umbrella organisation for more than 280.000 tax professionals from France, Germany, Italy, Belgium, Romania, Hungary and Austria. ETAF thanks the Commission for the opportunity to comment on the above-mentioned roadmap. ETAF welcomes the attention of the European Commission towards the topic of fair taxation and the need to act both against tax frauds and in favour of simplified tax rules, in order to ensure a level playing field in the internal market and support businesses to thrive. We strongly believe that the two topics are closely related since simplified tax rules are the first and strongest deterrent against tax frauds. During the last mandate, the European Commission carried out an excellent work in tackling tax evasion and enhancing tax transparency rules. ETAF appreciates that the focus is now also pointed at making tax compliance easier for businesses and individuals. This will ensure a reduction not only of tax frauds but also of mistakes that taxpayers often make which result in a loss of revenues for EU Member States. ETAF would like to draw attention to the special function of a specific professional group which is the interface between taxpayers and the state, namely European tax advisers. Tax advisers work very closely with the client. They advise, explain and justify why and which amount of taxes needs to be paid. As a result, European tax advisers make an important contribution to public acceptance of taxes and thus help strengthening tax compliance in society. However, such a “binding function” can only work if tax advisers themselves are obliged to comply by law. Unfortunately, this is far from being the case in all Member States. This is where a European solution should be put into place. An approach at European level could be to legally bind tax advisers themselves to Tax Compliance. In practice, this would mean they would be obliged to ask their clients to act in full compliance with the law and they would need to ignore/reject any calls for "non-compliance" of their clients or even resign from their mandate. In particular, we would like to highlight that the following aspects of professional law can lead to the strengthening of tax compliance: • The legal obligation to fully comply with the law and the high quality of tax advice guarantee the correct application of tax law and secure the tax revenues of the State. • The system of reserved activities protects companies, organizations and consumers from the consequences of poorer advice given by low-skilled/less qualified people. It therefore helps them to properly fulfil their tax obligations. • The shareholding requirements guarantee the independence of tax advisers and prevents the latter from becoming an extended arm of insurance companies or fund providers. This ensures that tax advisers work for their clients and not in the interests of external investors. • A high level of qualification for tax advisers ensures high-quality tax advice. The requirements for their training and further professional development must not be reduced in order to maintain the quality of their services. Ultimately, a continuous professional training of tax advisers has a positive effect on their clients’ tax compliance. Conclusion: The potential that tax advisory services/tax advisers can have to secure tax revenues of Member States has not yet been fully exploited in Europe. In each Member State, tax advisers should be given a responsible binding function between taxpayers and the State. A tax adviser's duty to comply can make a significant contribution to taxpayers’ tax compliance.
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Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis)

22 Nov 2019 · New taxation initiatives of the next European Commission

Response to Practical arrangements for Member States for implementing administrative cooperation in the field of taxation.

14 Feb 2019

The European Tax Adviser Federation (ETAF) welcomes the project of the European Commission to further harmonize the documentation concerning the exchange of information between Member States on reportable cross-border arrangements. ETAF acknowledges the positive impact of a streamlined procedure to be followed by the tax administrations to gather and share the necessary data on these arrangements with other tax authorities. In particular, ETAF recognizes that the proposed inclusion of an additional field in the standard form (containing a reference number identifying each reportable cross-border arrangement), shall enhance the efficiency of tax administrations of the involved Member States in recovering such information, when needed. Furthermore, it should simplify the work of tax administrations while providing them with an appropriate amount and quality of data. Overall, ETAF believes that standardization will bring positive results in terms of quantity of information shared between the Member States. Finally, ETAF observes that the amendment hereby proposed by the European Commission shall positively impact the way in which companies located in more than one Member State deal with the respective tax administrations.
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Response to Tax dispute resolution mechanism

14 Feb 2019

The European Tax Adviser Federation (ETAF) welcomes the intention of the European Commission to streamline procedures and harmonize documents concerning the rules of functioning of tax dispute resolution between Member States. ETAF believes that the design of a procedural framework for the effortless progress of the dispute resolution procedures, should guarantee an easier functioning of the Advisory Commission or Alternative Dispute Resolution Commission introduced with the Directive 2017/1852. In particular, ETAF acknowledges the project of the European Commission to supplement the Directive (EU) 2017/1852 with a form including standardized rules of functioning of the Advisory Commission or Alternative Dispute Resolution Commission and with a standard form for the communication of information concerning publicity of the final decision. ETAF recognizes that the draft of these forms included as annexes in the “Draft implementing regulation Ares(2019)276560” are based on what is included in article 11 and 18 of the Directive 2017/1852. ETAF believes that these types of standardized forms are helpful instruments for enhancing cooperation between Member States. Furthermore, ETAF considers them as useful tools to render the Rules of Functioning for the Advisory Commission or Alternative Dispute Resolution Commission more comprehensible for taxpayers involved in these tax disputes. Finally, ETAF welcomes the standardization of forms to be used for the communication concerning the publicity of the final decision.
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Response to More efficient law-making in taxation: a move to QMV

17 Jan 2019

Feedback on the Roadmap of the European Commission “More efficient law-making in the field of taxation: Identification of areas for a move to qualified majority voting” The European Tax Adviser Federation, ETAF, is a European umbrella organisation for more than 250.000 tax professionals from France, Germany, Italy, Belgium, Romania and Hungary. ETAF thanks the Commission for the opportunity to comment on the above-mentioned roadmap. The intention of the Commission to shift from unanimity towards qualified majority in EU tax legislation can have far-reaching consequences on the EU policy making in taxation and can therefore be considered as a politically highly sensitive area. However, it cannot be denied that the current situation – under which any legislative tax measure requires unanimity according to the Treaties – stands in contrast to most other policy areas where the ordinary legislative procedure has increasingly been used. Tax policy is in fact one of the last remaining political areas where unanimity is obligatory. ETAF takes the position that the arguments of the Commission should not be entirely dismissed: The unanimity principle stems from a time when the Union was smaller and unanimity therefore easier to achieve. In particular, in today’s EU, the progress in tax policy is sometimes hampered by the unanimity requirement which makes it often difficult for the Union to keep pace with rapid economic, societal and technological developments. Qualified majority voting could, for instance, help advancing the CCCTB and Digital Services Tax and at the same time, reduce the influence of certain Member States that are blocking reforms in European tax policy. Therefore, the discussion about how we can cautiously move on to qualified majority in some selected tax areas should not be refused. At the same time however, the objections raised by several national governments – namely the concern of losing fiscal sovereignty rights – shall neither be ignored. The national power of choosing tax strategies which meet the specific economic reality and the needs of that Member State should be a valid reason and thus taken seriously and carefully weighed up. Moreover, tax policy is also always budgetary policy. The proposal will therefore trigger interesting discussions about the relation between the general EU interests vis-à-vis the requirements of national sovereignty. Based on the structure of article 48 (7) TEU, it is likely that the question of a limitation in time of the additional transfer of sovereignty rights to the Union will arise. A national parliament might not be willing to be bound forever to its non-use of the veto, thus binding at the same time the Member State it represents. Furthermore, the political climate may change and the political will might no longer be strong enough to transfer sovereignty rights to the European Union. Nevertheless, according to ETAF, a careful selection of tax areas to be opened for qualified majority does not necessarily mean a loss of sovereignty, but can rather constitute a prerequisite for the European Union being taken as a serious tax legislator in the world. As a precaution, ETAF points out that a precise identification and enumeration of the concerned tax area will be essential in order to ensure the operational practicability of such a decision, to establish legal certainty and to avoid preliminary legal disputes about competences or the respective legislative procedure to be chosen. ------------------ Brussels, 16 January 2019
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Meeting with Stephen Quest (Director-General Taxation and Customs Union)

23 May 2018 · Conference “How to ensure fair taxation in a digitalized world?”

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

23 Nov 2016 · Commission’s proposals aiming at improving the Single Market and at fighting against tax fraud and tax evasion

Meeting with Antoine Kasel (Cabinet of President Jean-Claude Juncker)

4 Jul 2016 · Discuss ETAF Conference

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

16 Jun 2016 · Introductory presentation

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

26 Apr 2016 · current priorities in the field of taxation

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and ARCTURUS GROUP

12 Apr 2016 · Anti Tax Avoidance Package