CFE Opinion Statement on Simplification of the Directive on Administrative Cooperation & EU Corporate Tax Directives
CFE Opinion Statement 2/2025
The opinion statement expresses support for simplification and modernisation of the EU’s Directive on Administrative Cooperation (DAC) and corporate tax directives, in order to simplify EU tax law for a more competitive Single Market.
According to CFE these reforms would support the EU’s strategic goals of competitiveness, legal clarity, and administrative efficiency, while reducing unnecessary burdens on taxpayers and advisers alike.
With layers of amendments added to the Directives over time, CFE sets out its view in the statement that these EU frameworks have become dense, have led to inconsistent implementation, and are administratively burdensome—particularly for SMEs and cross-border operators.
As the EU prepares legislative proposals expected in 2026, CFE urges the Commission to seize this opportunity to create a more coherent, user-friendly legal framework that balances compliance efficiency with legal certainty. Our recommendations focus on streamlining rules, improving dispute resolution, and on reflecting today’s economic and digital realities.
Executive Summary
- A recast of the DAC to consolidate and clarify obligations and hallmarks;
- Harmonised penalties and legal privilege standards to ensure fair treatment across Member States;
- Codification of anti-abuse tests and beneficial ownership rules to reduce fragmentation;
- Support for the FASTER initiative and EU-wide digital withholding relief processes;
- Targeted updates to the Merger Directive, including clearer rules for share swaps, tax deferrals, and hybrid entities;
- Advocacy for permanent Advisory Commissions under the Dispute Resolution Mechanism to enhance procedural fairness and efficiency.
