EU Tax Simplification: DAC recast and Tax Omnibus

The DAC recast: simplifying tax transparency

Since its introduction in 2011, the DAC has become the cornerstone of tax transparency and information exchange within the EU. With multiple amendments (DAC1 to DAC9), the framework has expanded considerably, introducing new reporting obligations and exchange mechanisms designed to combat tax evasion and improve cooperation between tax authorities.

While these measures have strengthened transparency, they have also created a complex and fragmented system. The European Commission (EC) is therefore preparing a comprehensive DAC recast, which aims to consolidate the existing framework.

Key objectives of the DAC recast

The EC intends to move beyond simply collecting large volumes of tax information and instead focus on ensuring that data is accurate, usable and efficiently exchanged between tax authorities. The proposed reforms are expected to include:

• consolidation of the current DAC framework into a single legal instrument;
• simplification of reporting obligations and removal of unnecessary administrative requirements;
• elimination of overlapping reporting obligations, particularly where similar information is already reported under different regimes;
• greater harmonisation of reporting templates, deadlines and implementation across Member States;
• improved use of tax data through enhanced digital tools and analytical capabilities; and
• development of more integrated systems for taxpayer identification and information exchange.

DAC6 under review

Particular attention is expected to be given to DAC6, the mandatory disclosure regime for cross-border arrangements.

Stakeholders and tax administrations have consistently highlighted challenges arising from divergent interpretations of DAC6 hallmarks, extensive precautionary reporting and short reporting deadlines. The Commission is therefore considering:

• Reviewing and simplifying individual DAC6 hallmarks;
• Removing hallmarks that create significant reporting burdens without generating meaningful information;
• Extending reporting deadlines beyond the current 30 day period; and
• Providing greater consistency across Member States through clearer guidance and common implementation standards.

Tax Omnibus: simplifying EU tax directives

Next to the DAC recast, the EU is preparing a Tax Omnibus package designed to review and simplify several important EU tax directives. The initiative forms part of the broader programme to reduce regulatory burden and improve the competitiveness of businesses operating within the EU.

The simplification package is expected to cover: the Parent-Subsidiary Directive, the Interest and Royalties Directive, the Tax Merger Directive, the Anti-Tax Avoidance Directive (ATAD) and the Tax Dispute Resolution Mechanisms Directive.

The Tax Omnibus is intended to improve the functioning of existing legislation. The EC has indicated that the focus will be on identifying outdated provisions, eliminating overlaps and inconsistencies, and reducing unnecessary compliance burden.

Attention points

Based on discussions held by the Commission and stakeholders, the Tax Omnibus is expected to address:

• Administrative procedures that delay access to tax reliefs;
• Inconsistencies in the interpretation of EU tax rules between Member States;
• Duplicative documentation requirements;
• Legal uncertainty surrounding anti-abuse concepts and beneficial ownership tests; and
• Areas where existing legislation overlaps with newer tax initiatives.

The objective is to create a more coherent framework that allows businesses to benefit from EU tax reliefs more efficiently while maintaining appropriate safeguards against abuse.

Forvis Mazars contributes to the EC call for evidence

As part of the EC consultation process, Forvis Mazars submitted a response to the call for evidence on the Tax Omnibus initiative in March 2026.

Following the research conducted across several EU Member States through the Forvis Mazars international network, our contribution focused on the practical challenges businesses encounter when applying existing EU tax directives.

Our analysis found that many of the difficulties businesses face do not stem from the directives themselves, but rather from differences in their implementation and administration across Member States.

Practical challenges identified

Forvis Mazars submission highlighted several recurring issues, including:

• Repeated requests for documentation by different tax authorities;
• Divergent interpretations of beneficial ownership and anti-abuse provisions;
• Lengthy withholding tax relief and refund procedures;
• Lack of clarity regarding evidentiary requirements; and
• Increased compliance costs and administrative burdens for cross border groups.

These issues often create delays, uncertainty and unnecessary complexity for businesses seeking to access tax reliefs that are already available under EU law.

Recommendations from Forvis Mazars

To improve the effectiveness of existing directives, we have recommended that the EC focus on practical procedural simplification, including:

• Establishing relief at source as the default mechanism where eligibility conditions are met;
• Introducing more harmonised documentation requirements at EU level;
• Providing clearer guidance on beneficial ownership, substance and anti-abuse concepts; and
• Enhancing cooperation between tax authorities through mutual recognition of evidence and enforceable administrative timelines.

These measures would help reduce duplication, improve predictability and strengthen legal certainty while preserving proportionate anti-abuse protections.

The full Forvis Mazars response to the EC call for evidence can be accessed here: Feedback from: Forvis Mazars

More information on our public policy activities is available in our dedicated Tax section: Our contributions to public consultations – Forvis Mazars

Looking Forward

The publication of the DAC recast and Tax Omnibus proposals on 24 June 2026 will represent a significant milestone in the European Commission’s tax simplification agenda. While legislative discussions will continue, both initiatives signal a clear intention to create a more streamlined, coherent and business-friendly tax environment across the European Union.

Forvis Mazars will continue to monitor developments closely and provide timely updates on the implications for businesses across Europe. For more information Contact Ivana van der Maas