Booking.com B.V.

​​ ​ ​ ​ Contribution to public consultation on EU rules on administrative cooperation in the field of taxation (DAC) February 2026 The European Commission’s Competitiveness Compass, presented in January 2025, sets simplification of EU regulation as one of the enablers of European competitiveness across all sectors. Booking.com welcomes the intention to address regulatory complexities, overlaps and fragmentation, including those raised in the application of the Directives on Administrative Cooperation (DAC). We believe there is an opportunity to streamline requirements, thus also creating the conditions to deliver more effectively the desired policy outcomes. We strongly welcome the Commission’s intention for a comprehensive evaluation of the DAC from DAC1 to DAC9.

We strongly welcome the Commission’s intention for a comprehensive evaluation of the DAC from DAC1 to DAC9. In particular, we believe simplifications to DAC7 can create the biggest impact for businesses and unlock competitiveness without jeopardising the value and usefulness of data provided to Member States’ tax authorities. DAC7 as well as ViDA, CESOP and DSA have tried to tackle tax gaps and increase transparency in business user activity from different perspectives, introducing reporting requirements or collect and remit obligations that duplicate or conflict with one another, making compliance complex and creating significant administrative burdens for reporting platforms but also reportable businesses which are in their majority micro or SMEs. At the same time, diverging national rules and lack of uniform enforcement reduce legal certainty and increase compliance burdens.

…time, diverging national rules and lack of uniform enforcement reduce legal certainty and increase compliance burdens. As policy-makers are working towards this recast and a Tax Simplification Omnibus, we believe this is a unique opportunity to address these concerns. Booking.com is available to provide further input to the discussions based on our experience with legislation in practice. The DAC7 challenge and the need for simplification DAC7 (applying as of January 2023) requires platforms to share detailed information about some of their business partners (in Booking.com’s case mainly providers of short-term rentals) and transactions across the EU. This information is then exchanged between Member States.

…of short-term rentals) and transactions across the EU. This information is then exchanged between Member States. Gathering that information and reporting it to the relevant national tax authority, within the timelines set out in the Directive, is a significant undertaking for reporting businesses. Indicatively, it took the involvement of more than 10 teams, and more than 100 Booking.com employees over almost 3 years to prepare the business for compliance. We outline below our recommendations about how we can remove complexities in DAC7 implementation and enable more streamlined reporting while still serving the objective of the law: 1 Ref.

…in DAC7 implementation and enable more streamlined reporting while still serving the objective of the law: 1 Ref. Ares(2026)1491517 - 10/02/2026 ​​ ​ ​ ​ a.​ Simplify the list of data points required to address excessive data reporting Under DAC7, platforms such as Booking.com are required to request and collect data which appears excessive to the aims of the Directive. For example: 3 forms of business ID for each partner or some personal details such as Place of Birth which differ in format between Member States and may add very little to Member States ability to investigate traders given they already have the name, address and identification number of the trader. Furthermore, many Member States have not implemented sufficient systems for reporting businesses to verify or validate this data before submitting to the tax authorities.

…sufficient systems for reporting businesses to verify or validate this data before submitting to the tax authorities. We believe it is necessary to create one source of truth for verification and validation across the EU (perhaps managed by the European Commission). Excessive data reporting results in the increased requirement for data collection, storage, validation, verification and testing with tax authorities and each of these processes requires significant investment in communications and data collection infrastructure by platforms. Data points that are not strictly necessary but are required under DAC7 result in significant additional compliance costs for businesses across the EU.

…necessary but are required under DAC7 result in significant additional compliance costs for businesses across the EU. In this light we recommend that only three data points are required for reporting: 1)​ the name of the individual or business; 2)​ the Tax Identification Number (TIN); and 3)​ The registered business address or personal address. These three elements allow the tax authorities to identify the relevant tax payer and obtain sufficient information to carry out relevant further investigations. Other elements that are currently required such as the VAT registration number, Business registration number, Date of Birth, Place of Birth are attainable via reporting of the TIN.

…number, Business registration number, Date of Birth, Place of Birth are attainable via reporting of the TIN. The rationalisation of the list of data points required will result in a significant relief of the administrative burden for reporting and reportable businesses, allowing them to focus on delivering the experience travelers and businesses desire. In addition, we understand that the Commission has been considering removing the requirement for platforms to report on very large sellers as a simplification measure for platforms. This would be in addition to the existing exclusion for properties that accept more than 2000 bookings per annum. It is our view that such a change would not provide any significant savings for platforms or the large sellers.

…annum. It is our view that such a change would not provide any significant savings for platforms or the large sellers. Differentiating between large and small sellers would require further regular monitoring of sellers’ sales volumes by platforms and could lead to errors. In our view, reducing the number of data points in each seller rather than reducing the number of sellers would bring about the most savings for both platforms, sellers and tax authorities. b.​ Remove duplication of reporting requirements With national requirements 2 ​​ ​ ​ ​ The EU level implementation and sharing of data should in principle remove the need for separate reporting of the same or similar information at national level.

…data should in principle remove the need for separate reporting of the same or similar information at national level. However, businesses like Booking.com are still being asked to separately report in other Member States (such as Austria, Ireland or Spain) based on national (and even regional or local) legislation predating DAC7 which has not been yet withdrawn. This results in double reporting in different formats but also frequency, adding significant administrative burdens on reporting platforms. For example, in Austria, under VAT law, we are subject to an annual reporting requirement of data similar to the DAC7 (the name, address, VAT or TIN, bank account number of the seller; the consideration; etc.). We have also seen national implementation adding the reporting of land registration numbers (LRN) relevant to the property as listed on accommodation platforms.

…adding the reporting of land registration numbers (LRN) relevant to the property as listed on accommodation platforms. Tax Authorities have incorrectly used LRNs to assess tax on individuals who are not in receipt of the relevant income. For example, a host may be a relative of the property owner or the LRN may refer to a number of properties each with separate owners and therefore tax will be wrongly assessed. We suggest that the Commission clarify that LRNs should not be the lone source of information to look for non-compliant hosts. In order to simplify and streamline reporting, we recommend that DAC7 clarifies that reporting requirements under DAC7 supersede reporting requirements for platforms and reportable businesses under similar national schemes.

…under DAC7 supersede reporting requirements for platforms and reportable businesses under similar national schemes. In such instances, affected Member States should be able to use the data sharing provisions under DAC7 to request relevant data from the platform’s resident Member State. With the DSA In addition, under both DAC7 and DSA (Art. 30 Traceability of traders), we are required to request and verify much the same data twice and do this at different timing based on the distinct timelines provided in the DSA and DAC7. For example, under DAC7 we are required to capture the Place of Birth of the trader but this is not required for DSA. Additionally, under the DSA we have to make it available on our website but then under DAC7 we also have to report it to authorities.

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