Companies & groups · NL
Dear Sir or Madam, We welcome the opportunity to provide feedback on the recast of the Directive on Administrative Cooperation (DAC), and in particular on the provisions relating to DAC7. We understand and support the objective of DAC7 to improve tax transparency and administrative cooperation in relation to activities facilitated by digital platforms. Digital platforms recognise their role in supporting tax compliance and have invested significantly in systems, processes and controls to implement DAC7, often within challenging timelines. From an operational perspective, however, certain aspects of the current DAC7 framework create practical challenges that could be addressed in the context of the DAC recast, in line with the Commission’s broader simplification and burden-reduction objectives.
…in the context of the DAC recast, in line with the Commission’s broader simplification and burden-reduction objectives. In particular, the existing reporting thresholds for the sale of goods result in a very large population of reportable sellers and transactions, including many cases involving low-value, low-frequency or incidental activity, such as individuals selling personal items rather than engaging in regular commercial activity. This has broader implications beyond compliance, as it may unintentionally discourage participation in the circular economy, where individuals seek to resell unused goods in a sustainable and resource-efficient manner. At the same time, this significantly increases operational workload for platforms across onboarding, due diligence, monitoring, data management and reporting processes.
…workload for platforms across onboarding, due diligence, monitoring, data management and reporting processes. A more targeted scope could help ensure that reporting efforts focus on economically meaningful activity, while reducing complexity for platforms and sellers alike. In addition, platforms face practical limitations in validating certain seller datapoints required under DAC7, most notably taxpayer identification numbers (TINs). In many cases, platforms collect seller information through structured processes, but have limited access to reliable or standardised verification mechanisms across Member States. As a result, validation is often restricted to technical checks such as format or completeness rather than confirmation of accuracy.
…validation is often restricted to technical checks such as format or completeness rather than confirmation of accuracy. This creates challenges in ensuring data consistency and completeness, increases follow-up and remediation efforts, and requires platforms to adopt cautious reporting approaches to manage compliance risk. These challenges are further compounded by uncertainty around due-diligence expectations, in particular regarding the level of checks platforms are expected to perform when collecting and validating seller information. This is further influenced by variations in the way DAC7 obligations are applied in practice across Member States, including the absence of interoperable or authoritative EU-level TIN validation interfaces.
…across Member States, including the absence of interoperable or authoritative EU-level TIN validation interfaces. Greater clarity on acceptable reliance on seller self-certification as an initial step, reasonable technical checks where verification tools are available, and proportionate remediation steps in case of inconsistencies would materially reduce legal uncertainty without weakening enforcement. Ref. Ares(2026)1493718 - 10/02/2026 DAC7 also operates alongside other EU and national reporting obligations, such as those under the Digital Services Act (DSA) and AML/KYC frameworks, which often involve overlapping data elements but different definitions, timelines or validation standards.
…frameworks, which often involve overlapping data elements but different definitions, timelines or validation standards. Greater alignment and reuse of already collected and verified data — including explicit permission to rely on DSA-aligned seller verification for DAC7 purposes where data elements overlap — could help reduce duplication and administrative burden without undermining policy objectives. In the context of the DAC recast, further consideration of proportionality, threshold levels, data validation constraints and harmonised EU-level guidance could help improve the practical functioning of DAC7. Such refinements would support effective administrative cooperation while making the framework more operationally sustainable for reporting platforms.
…effective administrative cooperation while making the framework more operationally sustainable for reporting platforms. This would also be consistent with the broader EU objective of strengthening Europe’s competitiveness by reducing unnecessary operational burdens for businesses, while preserving high standards of compliance and transparency. We trust that these observations will be helpful in informing the ongoing assessment and remain available to engage further should additional clarification be useful. Yours faithfully, Maarten Boer Director Tax & Treasury