Consultation on Disincentives for Advisors and Intermediaries for Potentially Aggressive Tax Planning SchemesConsultation period: From 10.11.2016 to 16.02.2017

Section in the questionnaire 1. Information about respondent

Introductory text to the question

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Questions

ResponsesDo you agree to your contribution being published?

Do you declare that the information you provide in your response to this consultation is not subject to copyright restrictions?

Consultation on Disincentives for Advisors and Intermediaries for Potentially Aggressive Tax Planning SchemesConsultation period: From 10.11.2016 to 16.02.2017

Please elaborate Please specifyThe information provided is not subject to copyright restrictions. Public authority, public institutions, including na [respondent wishes to The information provided is not subject to copyright restrictions. Public authority, public institutions, including na [respondent wishes to The information provided is not subject to copyright restrictions. Public authority, public institutions, including na BundesnotarkammerThe information provided is not subject to copyright restrictions. Public authority, public institutions, including na Österreichische NotariThe information provided is not subject to copyright restrictions. Public authority, public institutions, including na European Parliament

Important notice on the publication of responses

Please note: The European Commission will prepare a report summarizing the responses. Contributions received are thus intended for publication on the Commissions webiste (see specific privacy statement).

1. Are you replying as or on behalf:

2. Please indicate your name, or the name of your company, organisation or institution for which you respond to this consultation.

[respondent wishes to Yes. Spain[respondent wishes to Yes. Germanybnotk@bnotk.de Yes. Germanybruessel@notar.or.at Yes. AustriaMatt.Carthy@europarl.e Yes. Ireland

3. Please indicate your email-address. (Optional)

4. In case we have questions regarding answers or remarks you have provided, can we contact you?

5. Where do you live, or where is the headquarter of your company or organisation (main headquarters in case of multinational companies), or where is your public authority located?

If other country, please specify:

6. Is your organisation or the entity you represent included in the EU Transparency Register? (More information on the Transparency Register can be found here.)

Please indicate your Register ID number

7. Please indicate the size of your company in terms of current number of employees.

8. Please indicate the size of your company in terms of either the annual turnover, or the balance sheet total, whichever you consider more relevant. (This information is needed solely for the purpose to distinguish small and medium sized companies from large

Yes. Tax advisors;Financial (investment) advisors, accI don't know.Yes. Others Personal accountant, takNo.No.Yes. Tax advisors;Financial (investment) advisors, accoI don't know.No.

1. Do you (or the entity you represent) receive professional tax advice?

2. From whom do you (or the entity you represent) receive professional tax advice? (Please tick all applicable categories.)

If other, please specify:

3. When requesting advice on tax planning schemes, do you (or the entity you represent) request the intermediary to prepare a risk assessment? 

No.No.No.No.No.

Please provide further information

4. Would you consider yourself (or the entity you represent) to be a user of potentially aggressive tax planning schemes? (See the glossary for a definition of "potentially aggresssive tax planning scheme".)

1. Do you (or the entity you represent) provide professional tax advice?

2. When providing advice on tax planning schemes, do you (or the entity you represent) maintain contacts with the tax authorities to discuss the terms of the scheme?

2. Your opinion on the objectives of the policy initiative

Not useful at all Of limited use, e.g. only

Don't know Don't knowNot useful at all Don't know

Please describe the practice and indicate whether there is room for negotiation with the tax authorities.

3. Would you consider yourself (or the entity you represent) to be an intermediary for potentially aggressive tax planning schemes? See the glossary for a definition of "intermediary" and "potentially aggresssive tax planning scheme".)

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Confidentiality clause (See glossary)

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Premium fee (See glossary)

Very useful Very useful

Very useful Very useful

2. Your opinion on the objectives of the policy initiative

Of limited use, e.g. onlyNot useful at allOf limited use, e.g. only Don't know Don't knowOf limited use, e.g. only Of limited use, e.g. only Of limited use, e.g. onlyOf limited use, e.g. only

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Use of jurisdictions included in the (future) EU list of third country jurisdictions that fail to comply with tax good governance standards .

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Use of certain legal arrangement/entities (trusts and similar) in jurisdictions that pose difficulties to identifying the beneficial owner.

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Use of entities subject to zero taxation or less than a certain % (to be defined), including hybrid entities (i.e. entities that are treated as

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Schemes designed to circumvent the Common Reporting Standard (CRS) for automatic exchanges of financial account information.

Very useful Very useful Very usefulVery useful Very useful Very usefulVery usefulVery usefulVery useful Very useful Very useful

Of limited use, e.g. only Of limited use, e.g. only Of limited use, e.g. onlyOf limited use, e.g. only

Of limited use, e.g. only Don't knowOf limited use, e.g. only Don't know

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Use of a group company in a low tax jurisdiction for intra-group financing of other group companies in high tax jurisdictions.

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Use of group companies with very little substance that are nevertheless entitled to tax treaty benefits and through which large amounts of

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: A general artificial arrangement or an artificial series of arrangements created for the essential purpose of avoiding or evading taxation

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: A transfer pricing arrangement not in conformity with the arm's length principle and/or the OECD transfer pricing guidelines.

Very usefulVery useful Very useful Very usefulVery useful Very usefulVery useful Very usefulVery useful Very useful Very useful Very useful

Of limited use, e.g. only Of limited use, e.g. only in combination with other criteriaOf limited use, e.g. onlyDon't know Don't knowDon't know

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: A profit allocation between different parts of the same group not in conformity with the arm's length principle and/or the OECD transfer pricing

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: A preferential treatment under the application of the national tax law that is not in line with the general application or interpretation of the

1. In your view, how useful are the following criteria to classify tax schemes as potentially aggressive?: Other or additional criterion.

Please elaborate on other or additional criteria you would consider useful for the classification of potentially aggressive tax planning schemes.

Very useful Very useful - derivatives that avoid withholding taxesVery useful

Very useful Very useful Another useful criteria could be "no reliable data in the company register". In some Member States company registers do not contain verified data but rely on self-reporting. These non-transparent registers make it very difficult to find out beneficial ownership of a company. Henceforth unreliable company register contribute to aggressive tax planning schemes. Very useful Very useful Very useful

Other. As single criteria, the in Neutral. Agree.Yes. Agree very much. Agree very much.No opinion/I don't know. Neutral. Agree very much.No opinion/I don't know. Neutral. Agree very much.Other. Agree very much. Agree very much.

2. Should any tax planning scheme relating to countries appearing on the EU's (future) list of third country jurisdictions that fail to comply with tax good governance standards automatically qualify as a potentially aggressive tax planning scheme? Please elaborate:

3. To what extent do you agree with the following objectives to strengthen the fight against tax evasion and avoidance?: Dissuade intermediaries and users of potentially aggressive tax planning schemes from using them.

3. To what extent do you agree with the following objectives to strengthen the fight against tax evasion and avoidance?: Ensure that national tax authorities have timely access to relevant information on potentially aggressive tax planning schemes.

Disagree. Agree very much. Agree very much.Agree very much. Agree very much. Agree very much. Agree very much.Agree. Agree. Neutral.Agree very much. Agree very much. Neutral.Agree very much. Agree very much. Agree very much. Agree very much.

3. To what extent do you agree with the following objectives to strengthen the fight against tax evasion and avoidance?: Avoid distortions in the single market due to diverging reporting requirements as regards potentially aggressive tax planning schemes so

3. To what extent do you agree with the following objectives to strengthen the fight against tax evasion and avoidance?: Facilitate administrative cooperation between tax authorities to tackle cross-border abusee.

3. To what extent do you agree with the following objectives to strengthen the fight against tax evasion and avoidance?: Improve voluntary compliance of taxplayers by introducing reassurances on the fairness of the system.

3. To what extent do you agree with the following objectives to strengthen the fight against tax evasion and avoidance?: Other or additional objective to strengthen the fight against tax avoidance and evasion.

Disagree very much.Disagree very much.

A potential EU policy in EU MS should face this pNo opinion/I don't know.The cornerstone to fair A potential EU policy initiative should address a Yes, Member States should be made aware of poten

A potential EU policy initiative should focus onl Yes, Member States should be made aware of potenA potential EU policy in EU action should be targYes, Member States should be made aware of potenA potential EU policy in An EU policy initiative Other opinion.

Please elaborate on additional or other objectives to strengthen the fight against tax evasion and avoidance.

4. Should a potential EU policy initiative focus on those potentially aggressive tax planning schemes only when there is a cross-border aspect, or should it address any aggressive tax planning scheme irrespective of the location of the different elements? 

Please explain the rationale for your answer

5. Currently, only a small number of EU national tax authorities receive information on potentially aggressive tax planning schemes. In your view, should tax authorities in all Member States be made aware of potentially aggressive tax

Moreover it would be helpful to fight the tax law problems even on an upstream level: letterbox companies and companies set up by straw men should be made impossible. This could be achieved by prohibiting or limiting the option to separate the statutory seat and the seat of administration where the real business is located. A minimum standard would be to require a genuine link of the company to the State where it has registered its seat. Additionally, the data in company registers should be made more reliable by independent control of every entry by an impartial public office holder, such as the civil-law notary.There should be the possibility to publicly name promoters and taxpayers who fail to disclose, on a regular basis, potentially aggressive tax planning schemes to the relevant tax authorities. In extreme and repeated cases, the possibility of revoking the business license of the firm in question should also be a possibility, as recommended in Article 165 of the Final Report of the Special Committee on Tax Rulings of the European Parliament.

No opinion/I don't know. Yes, information should In any case subject to i NoYes, Member States should be made aware of potenOther opinion As soon as a country is OtherYes, Member States should be made aware of potenYes, information should It is important to receiv No opinion/Don't knowYes, Member States should be made aware of potenYes, information should More data on aggressive tNo opinion/Don't know

Yes, information should See response to questioYes

Please elaborate.  (Optional)

6. In your view, should national tax authorities share information on potentially aggressive tax planning schemes with tax authorities of other EU Member States?

Please elaborate. (Optional)

7. In the fight against tax evasion and avoidance, do you think that the EU should focus on the role of intermediaries who assist in potentially aggressive tax planning schemes?

All tax authorities should participate in information-sharing on aggressive international tax planning schemes, for example, through the Joint International Taskforce on Shared Intelligence and Collaboration, and a similar organisation could be established in the EU.

3. Tax Transparency

No, the exercise of the pDisagree very much NeutralDisagree very much Neutral Disagree very muchNeutral Neutral Neutral

Intermediaries can play aNeutral Neutral NeutralDisagree very much Disagree very much

Please elaborate. (Optional)

1. In terms of tax transparency, to what extent do you agree with the following statements?: Current EU legislation related to potentially aggressive tax planning schemes is sufficient. The EU should leave it to each Member State whether or not to implement the

1. In terms of tax transparency, to what extent do you agree with the following statements?: The EU should implement the recommendations issued at international level by the OECD in a coordinated way in order to ensure a level playing field within the European

1. In terms of tax transparency, to what extent do you agree with the following statements?: The EU should implement the recommendations issued at international level by the OECD at the same pace and to the same extent as its global partners in order to ensure a

Agree very much

The most efficient and reliable procedure is to involve public office holders who have the obligation to report tax relevant events to the financial authorities. Financial authorities gain directly and trustworthy knowlegde of the relevant cases. This also prevents costly and lengthy investigation procedings and sactioning procedures (especially for complex cross-border cases).

Agree very much

Likely LikelyThe EU should definitelyNeutral Very likely

Neutral Unlikely LikelyNeutral Likely Likely

The EU should be at the Unlikely Very likely

1. In terms of tax transparency, to what extent do you agree with the following statements?: The EU should be in the forefront in implementing the recommendations issued at international level.

Is there anything you would like to add?

2. In your view, if no action was taken at EU level, what would happen?: No transparency requirements would be introduced in the majority of Member States.

2. In your view, if no action was taken at EU level, what would happen?: Differing transparency requirements would be introduced in the different Member States.

Agree very muchAgree very much

Agree very much

I don't know. DisagreeUnlikely Very likely Action on EU level is im Agree completelyNeutral Agree completelyUnlikely I don't know. Agree completelyNeutral Agree completely

2. In your view, if no action was taken at EU level, what would happen?: Most Member States would likely follow closely OECD standards.

2. In your view, if no action was taken at EU level, what would happen?: Other effects.

Please elaborate on the "other effects".

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: A more focused enforcement action to ensure tax law compliance by

Neutral Neutral Disagree DisagreeAgree completely Agree completely Agree completely Agree completelyAgree completely Neutral Neutral NeutralAgree completely Agree Agree completely NeutralAgree completely Agree completely Agree completely Agree completely

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: A more focused enforcement action to ensure tax law compliance by

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: Dissuasive effect on intermediaries who assist in potentially aggressive tax

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: Dissuasive effect on users of potentially aggressive tax schemes.

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: Contribution to improving voluntary tax law compliance in general by providing

Neutral Neutral Agree completely NeutralAgree completely Agree completely Completely disagree AgreeAgree Agree Neutral AgreeAgree Agree Neutral AgreeAgree completely Agree completely Completely disagree Agree completely

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: Easier evaluation of national tax legislation with a view to detecting and

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: More effective cooperation between national tax authorities and thus

3. In your view, if advisors and intermediaries were obliged to report potentially aggressive tax planning schemes, what would be the direct consequences?: Increased burden on providers of tax advice that would be harmful to their daily

Economic Impacts: A better and fairer tax environment where all taxpayers pay their share of taxes.

Disagree Agree Neutral NeutralAgree completely Agree completely Agree completely DisagreeAgree Neutral Neutral NeutralAgree Neutral Agree NeutralAgree completely Agree completely Agree completely Agree

Economic Impacts: An increase on the taxes collected by tax authorities in the EU.

Economic Impacts: An increase on the taxes collected by tax authorities outside the EU.

Social Impacts: Deterrence of the use of aggressive tax planning schemes.

Social Impacts: Tax authorities focus their efforts on wealthy taxpayers.

Agree completely Neutral Neutral NeutralAgree completely Agree Agree completely Agree completelyAgree Agree Agree NeutralAgree Agree completely Agree AgreeAgree completely Agree Agree completely Agree

Social Impacts: Voluntary tax compliance by taxpayers will improve.

Administrative burden: The increase of administrative burden and costs due to the new disclosure obligations will deter using potentially aggressive tax planning schemes.

SMEs, competitiveness and innovation: SMEs will benefit from a level playing field as big enterprises will have fewer opportunities to use potentially aggressive tax schemes.

SMEs, competitiveness and innovation: An increased level playing field between all companies should result in increased competitiveness.

Disagree Agree completely Disagree AgreeAgree Completely disagree Agree completely NeutralNeutral Neutral Neutral DisagreeNeutral Disagree Neutral DisagreeNeutral Completely disagree Agree Agree

SMEs, competitiveness and innovation: An increased level playing field between all companies should result in increased innovation.

SMEs, competitiveness and innovation: Mandatory disclosure obligations will reduce the attractiveness of the EU Internal Market.

SMEs, competitiveness and innovation: EU Action would constitute a feature of a growth friendly environment and foster the attractiveness of the EU as a place to invest.

Public Administrations: Mandatory disclosure requirements will increase administrative burden for public authorities.

4. Mandatory Disclosure Obligations

Disagree Neutral Yes.Agree completely Agree completely No.Agree Agree Yes.Agree Agree Yes.Agree completely Agree completely Yes.

Public Administrations: The benefits of mandatory disclosure requirements will outweigh the burden to public administrations.

Third countries: Decrease in the services provided by firms/professional located in the jurisdictions considered as non-cooperative jurisdictions to EU taxpayers.

Are there any other impacts you would like to indicate?

1. In your national legislation, are there mandatory disclosure obligations for taxpayers involved in potentially aggressive tax planning schemes? 

4. Mandatory Disclosure Obligations

After a recent reform, t Yes, to some extent. As long as there are regYes, to some extent.

I don't know.The problem with mandatorI don't know.

Yes, to some extent.

Please describe them and provide your opinion e.g. with regard to their effectiveness.

In your view, did the use of tax planning schemes change following the introduction of mandatory disclosure obligations for taxpayers?

In your view, would the introduction of mandatory disclosure obligations for taxpayers change the use of tax planning schemes?

Please provide further information. (Optional)

The most efficient and reliable procedure is to involve public office holders who have the obligation to report tax relevant events to the financial authorities. Financial authorities gain directly and trustworthy knowlegde of the relevant cases. This also prevents costly and lengthy investigation procedings and sactioning procedures (especially for complex cross-border cases).

Revenue's guidance is here: www.revenue.ie/en/practitioner/.../guidance-notes-mandatory-disclosure-regime.pdf

No. Yes, to some extent.No. Yes, to some extent.Yes. Any registration proceduYes, to some extent.Yes. Yes, to some extent.Yes. See explanation above i Yes, to some extent.

2. In your national legislation, are there mandatory disclosure obligations for intermediaries who assist in potentially aggressive tax planning schemes? 

Please describe them and provide your opinion e.g. with regard to their effectiveness.

In your view, did tax advice practice change following the introduction of mandatory disclosure obligations for intermediaries?

In your view, would the introduction of mandatory disclosure obligations change tax advice practices for intermediaries?

No.I don't know whether there exists a code of conduct or ethic rules on the use of potentially aggressive tax planning schemeYes. Notaries are subject to sYes, to a large extent.Yes. Yes, to some extent.I don't know whether there exists a code of conduct or ethic rules on the use of potentially aggre

Please provide further information. (Optional)

3. In your legislation, are intermediaires subject to a code of conduct or ethic rules on the use of potentially aggressive tax planning schemes?

Please describe them and provide your opinion e.g. with regard to their effectiveness.

In your view, did tax advice practice change following the introduction of a code of conduct or ethic rules?

Above all the main change would be the increase of bureaucracy and costs for the clients and administrations (and public law bodies with delegated disciplinary competences). It would not necessarily improve the results of the tax fraud control.

In some areas notaries assist the Austrian state in raising taxes. For example notaries can calculate and transfer to the state the real estate tax due for any real estate transaction. Even if the client decides to self-calculate and transfer the tax, the notary is still obliged to report the real estate transaction to the state to ensure tax transparency. The involvement of notaries is made even more trustworthy through a double-control providing strict supervision by the ministry of justice and the presidents of the Higher Regional Courts on the one hand, and by the Austrian Chamber of Civil-law notaries on the other hand.

No. The conduct of conduct oblOther. Yes but only together wiI don't know whether there exists a code of conduct or ethic rules on the use of potentially aggressive tax planning schemeYes. A high degree of transpa

The Federal Code of NotarNo. Every state should be abAustrian notaries have pNo. Member States should be a

I don't know whether there exists a code of conduct or ethic rules on the use of potentially aggre By their nature, professi Yes.

In your view, would the introduction of a code of conduct or of ethic rules change tax advice practice?

Please provide further information. (Optional)

4. Do you think that there is a need to impose mandatory disclosure obligations with respect to potentially aggressive tax planning schemes?

Please explain the rationale for your answer. (Optional)

Please specifyTaxpayers who make use of potentially aggressivYes, in such cases the t It should always be the Both, taxpayers and intermediaries, who make useYes, in such cases the tIntermediaries who assist in potentially aggressi No opinion/I don't know. It would be preferrable Intermediaries who assist in potentially aggressi No opinion/I don't know. N/AOther opinion. Yes, in such cases the t Yes - but as outlined in

5. Mandatory disclosure obligations on potentially aggressive tax planning schemes can require disclosure from taxpayers (the users) and/or intermediaries. Whom should a policy initiative oblige to disclose the

6. In some cases, there might not be any intermediary for tax planning, for instance when a tax planning scheme is developed "in house" of an enterprise. In other cases, intermediaries might not be subjected to mandatory discolusre obligation, as the intermediary is

Please explain the rationale of your answer

When the intermediary is located in a third country, they should still be made to disclose information. This could be achieved by imposing sanctions on them if they do not comply.

In cases where the promoter is located offshore, the disclosure obligation should fall on both the taxpayer and the offshore intermediary. Where there are enforcement concerns and/or practical difficulties in ensuring compliance by offshore promoters, sanctions should be considered, including for example denial of the right to participate in public contracts.

Very useful Not useful Useful Not usefulVery useful Very useful Very useful Very usefulVery useful Very useful Neutral UsefulVery useful Very useful Useful UsefulVery useful Very useful Very useful Very useful

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Identification of the taxpayer (user of the potentially aggressive tax planning scheme)

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Identification of the intermediary

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Details of the potentially aggressive tax planning scheme.

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Details of the provisions/hallmark that qualifies the tax planning scheme as potentially

Not useful Useful Neutral NeutralVery useful Very useful Very useful Very usefulNeutral Neutral Neutral NeutralNeutral Neutral Neutral NeutralVery useful Very useful Very useful Very useful

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Statutory/regulatory provisions on which tax advantage is based.

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Identification of the different jurisdictions used in the scheme.

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Description of the tax benefit or advantage.

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Amount of the tax benefit or advantage.

Not usefull at all Not usefull at allVery useful Very usefulNot useful UsefulNot useful Useful I don't know N/AVery useful Very useful Very useful

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Disclosure obliations only to intermediaries: List of clients advised/linked

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Disclosure obliations only to intermediaries: Member States of residence of

7. In your view, what information should be provided on potentially aggressive tax planning schemes? How useful would you consider the individual items?: Other or additional information

Please elaborate the other or additional information that you consider useful to be disclosed.

5. Policy Options and their impacts

- - - -0 0 0 00 0 0 0- - - -

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

- 0 0 -0 0 + 00 0 0 00 - 0 -

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

0 0 + 00 0 + +0 0 + ++ 0 + 0

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

+ 0 + +0 + 0 ++ + + ++ 0 0 +

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

+ + + ++ 0 + 0+ + + ++ + + 0

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

+ + + +0 0 0 +0 0 0 0+ + + +

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

+ - - -0 0 0 00 - - -+ - - -

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

Neutral- -0 0 Neutral- - Neutral- -

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

1. In your view, which policy option is best suited for obtaining the objectives? Please rate below how well each option would achieve the identified primary objectives (+ (plus) achieves the objective, 0 (zero)has no effect with respect to the objective, - (minus) runs counter

2. In your view, how effective would the policy options be in terms of introducing disincentives for tax payers using and intermediaries assisting potentially aggressive tax planning schemes?: Option 0: No action at the EU level

2. In your view, how effective would the policy options be in terms of introducing disincentives for tax payers using and intermediaries assisting potentially aggressive tax planning schemes?: Option A: Encourage Member States to use currently available exchange of Of limited effectiveness

Not effective at all Not effective at allOf limited effectivenessOf limited effectiveness

Not effective at all Not effective at all

Effective EffectiveEffective Very effective

Effective Effective NeutralEffective Very effective Neutral

Effective Very effective

2. In your view, how effective would the policy options be in terms of introducing disincentives for tax payers using and intermediaries assisting potentially aggressive tax planning schemes?: Option B: Disclosure of information

2. In your view, how effective would the policy options be in terms of introducing disincentives for tax payers using and intermediaries assisting potentially aggressive tax planning schemes?: Option C: Disclosure and Exchange of information

2. In your view, how effective would the policy options be in terms of introducing disincentives for tax payers using and intermediaries assisting potentially aggressive tax planning schemes?: Option D: Disclosure (Option B) or Disclosure and Exchange of

2. In your view, how effective would the policy options be in terms of introducing disincentives for tax payers using and intermediaries assisting potentially aggressive tax planning schemes?: Option E: EU Code of Conduct

Of limited effectiveness Not effective at allOf limited effectiveness Not effective at all

Not effective at allNot effective at all

Of limited effectiveness Of limited effectiveness

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The_policy_lines_detected_by_the_inception_assessment_of_the_EC_are_heavily_conditioning_the_questionnaire_and_the_lines_of_action.odt