KPMG maps EU tax proposal to streamline multinational reporting
The Commission’s DAC recast would let some multinationals use one notification for CbCR and Pillar Two, while tax teams still face new data and filing plumbing.

The European Commission’s DAC recast would let some multinational groups file one combined notification instead of managing separate processes under country-by-country reporting and Pillar Two. For tax teams, the immediate operational shift is clear: the paperwork may shrink, but the data, controls and cross-border sign-off behind it still have to be rebuilt around a single workflow.
The Commission published the proposal on 24 June 2026 as part of a broader tax simplification package. The recast consolidates and simplifies Directive 2011/16/EU and brings together DAC1 through DAC9 into a more coherent text after years of successive amendments left the framework fragmented and complex. The goal is to reduce administrative burdens for businesses while keeping the EU’s tax transparency regime intact.

The first burden will land on the teams that own the underlying data. The proposal’s single-notification approach for certain MNE groups in scope of CbCR and central filing of top-up tax information returns should reduce duplicate filing steps, but it will also force companies to align entity data, jurisdictional reporting calendars and approval chains across regimes that were built separately.
The same package also reaches beyond multinational groups. The Commission’s factsheet puts the number at more than 10 million private sellers, especially people selling second-hand goods, whose reporting obligations would be removed. Other changes would streamline mandatory disclosure rules by adjusting exemptions, deadlines and the treatment of intermediaries covered by legal professional privilege, while also refining platform operator rules, beneficial ownership information for real estate and a digital tool to verify tax identification numbers.
Some obligations are being pared back, but others are being reorganized into more data-intensive systems that will need tighter governance, new filing logic and clearer escalation routes when legal privilege or cross-border disclosure questions arise. KPMG submitted feedback during the consultation phase, which closed on 10 February 2026, after the Commission opened the broader simplification work.
The core problems are disproportionate compliance requirements, legal uncertainty, divergent treatment across Member States and cross-border tax barriers. The Regulatory Scrutiny Board gave the draft a positive opinion with reservations, including concerns about how the recast fits with related measures such as public country-by-country reporting.
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