European Holiday Home Association

EHHA RESPONSE TO THE PUBLIC CONSULTATION ON THE POSSIBLE RECAST OF THE DIRECTIVE ON ADMINISTRATIVE COOPERATION IN DIRECT TAXATION (DAC) Executive Summary: The European Holiday Home Association (EHHA), a voice of short term rental (STR) accommodation players in Europe, supports the objective of improving STR tax transparency. DAC7 has contributed to increased visibility of STR income and has shown preventive effects in some Member States. However, implementation experience across the STR ecosystem demonstrates that the framework, as currently designed, requires significant resources from reporting and reportable businesses, does not sufficiently reflect the structural reality of STR booking models, and has created disproportionate compliance burdens — particularly for SMEs and micro-operators.

…of STR booking models, and has created disproportionate compliance burdens — particularly for SMEs and micro-operators. STR booking and payment chains are structurally multi-layered and frequently involve multiple intermediaries performing different roles, including platforms, property managers, agents, channel managers, software providers, and marketing intermediaries. There is often no single actor that controls the full transaction and payment flow. DAC7 reporting rules, which rely heavily on the “guest–platform–host” model, have therefore generated significant uncertainty over who must report. In combination with the complexity of the reporting framework and overlaps with ViDA, CESOP and DSA this has led to duplicate and over-reporting, inflated datasets, and additional reconciliation burdens for tax authorities.

…has led to duplicate and over-reporting, inflated datasets, and additional reconciliation burdens for tax authorities. What is equally important is that these complexities end up pressuring the SME and micro-enterprise accommodation and rental partners across Europe who are required to provide information for DAC7 purposes multiple times. DAC7 compliance obligations have also shifted substantial regulatory data-collection responsibilities onto private companies. STR intermediaries were required to build complex compliance infrastructures, redesign IT systems, conduct enhanced due diligence, collect sensitive tax data from hosts, and manage reporting and correction cycles at their own expense. Implementation costs have been substantial.

…hosts, and manage reporting and correction cycles at their own expense. Implementation costs have been substantial. These fixed compliance costs are disproportionately high for SMEs and micro-operators and have, in some cases, led smaller STR intermediaries to reduce digital booking functionality or move transactions offline — undermining digitalisation and transparency objectives. At the same time, DAC7 datasets are not yet demonstrably analysed or fully operationalised across Member States, while additional STR-related reporting regimes are being introduced at EU level, including under the Regulation (EU) 2024/1028 on the collection and sharing of data relating to short-term accommodation rental services (STR Regulation) and the VAT in a Digital Age (ViDA) package.

…data relating to short-term accommodation rental services (STR Regulation) and the VAT in a Digital Age (ViDA) package. This creates a growing risk of overlapping and partly redundant reporting obligations based on similar datasets, increasing compliance burden without clear evidence that existing data flows are fully utilised. Based on STR industry implementation experience, EHHA recommends that the DAC7 recast should: ●​ Explicitly recognise the structural complexity and multi-intermediary nature of STR booking chains and clarify that platforms should report on their contracted partners and if such partners are also acting as intermediaries to other underlying sellers, then the platform should not be obliged to report on those underlying sellers.

…to other underlying sellers, then the platform should not be obliged to report on those underlying sellers. In short, it needs to be specifically clarified that the reporting obligation should rest with the entity that contracts directly with the supplier. ●​ Introduce clear EU-wide reporting priority rules and avoid any duplicate-reporting with other national and EU rules (e.g. DSA, CESOP). ●​ Simplify the list of data points required to be reported on under DAC7 by requiring only the following three elements through which other information can be easily attained: name of the individual or business; the Tax Identification Number (TIN); and the registered business address or personal address. Ref. Ares(2026)1784419 - 17/02/2026 ●​ Require formal EU-level evaluation of DAC7 STR data usage and effectiveness before expanding platform obligations or adding any further STR regulatory layers.

STR data usage and effectiveness before expanding platform obligations or adding any further STR regulatory layers. ●​ Ensure interoperability across DAC7, STR Regulation, and ViDA through a “report once — use many times” principle. ●​ Introduce EU-level technical harmonisation and operational simplification measures for DAC7 reporting, including harmonised Member State tax portal standards, consistent financial data classifications, simplified net-payment reporting options, uniform treatment of cancellations and booking adjustments, and clear cross-border TIN guidance — to reduce cross-border reporting inconsistencies and technical burden, and ●​ Strengthen continuous awareness and communication requirements to support informed compliance.

…technical burden, and ●​ Strengthen continuous awareness and communication requirements to support informed compliance. A proportionate DAC7 recast grounded in operational market realities will improve data quality, reduce unnecessary administrative burden, protect SME participation, and increase the effectiveness of tax transparency objectives across the STR ecosystem. The detailed feedback on key DAC7 Implementation Concerns is provided below: 1.​ Uncertainty Over Who Must Report — Structural Complexity of STR Booking Chains DAC7 reporting obligations are built on an implicit assumption that STR transactions follow a relatively linear and platform-centric model — where a guest books STR accommodation through a single online platform, the platform processes the payment to the host, and that platform can therefore be treated as the clear and reliable reporting entity.

…the payment to the host, and that platform can therefore be treated as the clear and reliable reporting entity. In practice, this simplified model does not reflect how the STR market actually operates. As demonstrated in EHHA’s STR ecosystem (Annex 1), STR bookings are generated through multiple, often overlapping booking pathways involving a wide range of actors, contractual relationships, and technical arrangements. STR booking is structurally multi-layered rather than linear. Booking flows may involve online platforms, property managers, local letting agencies, travel agents, tour operators, trade association portals, co-hosts, nano-property managers, serviced apartment operators, and hybrid hospitality structures. Many STR properties are marketed across several channels simultaneously, and STR bookings frequently move between online and offline environments before being finalised.

…simultaneously, and STR bookings frequently move between online and offline environments before being finalised. Within these STR booking chains, actors perform very different functions — marketing, listing, distribution, booking facilitation, payment processing, property operations, and guest services — and they do so under different legal roles, including disclosed agency, undisclosed agency, or purely technical intermediation. As a result, there is frequently no single entity that controls the full STR transaction chain from listing to payment settlement. In many STR transactions, the entity that advertises the property is not the entity that contracts with the guest; the entity that contracts with the guest is not the entity that receives the payment; and the entity receiving the payment is not necessarily the underlying accommodation provider.

…receives the payment; and the entity receiving the payment is not necessarily the underlying accommodation provider. Platforms that generate the booking lead often do not control, process, or even see the final financial settlement. This structural reality creates significant uncertainty in determining DAC7 reporting responsibility. Companies frequently cannot establish with sufficient legal certainty whether: ●​ they qualify as the reporting platform operator in a given STR booking chain, ●​ whether they are acting as a platform or merely as a marketing/listing service, ●​ whether channel managers or software providers are in DAC7 scope, ●​ whether reporting responsibility shifts depending on payment flow, ●​ whether another intermediary is already reporting the same transaction, ●​ whether STR property managers reporting directly makes platform reporting duplicative.

…the same transaction, ●​ whether STR property managers reporting directly makes platform reporting duplicative. In STR distribution models, the practical distinction between online platforms, agents, software providers, channel managers, and marketing intermediaries is often not clear-cut. However, DAC7 reporting obligations rely heavily on these classifications, while the Directive does not provide sufficiently precise operational criteria to ensure consistent interpretation and application across Member States. Illustrative STR Booking Scenarios Demonstrating Duplicate Reporting Risk: Scenario A: Guest - Online STR Platform - Property Manager - Host In Scenario A, a guest books accommodation through an online platform acting as a disclosed agent, while the property itself is managed by a local property manager acting as an undisclosed agent for the host.

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