In late 2025, the European Commission opened a call for evidence and a public consultation to recast the Directive on Administrative Cooperation in direct taxation, widely known as DAC. The policy goal is straightforward: DAC has become one of Europe’s core anti-evasion tools, but it also grew into a complex stack of additions and uneven national implementations. That is why the Commission is exploring a consolidation of DAC1–DAC9 into a single legal instrument, paired with targeted fixes aimed at reducing duplicate reporting, improving data quality, and strengthening IT interoperability across Member States.
What the 2025 DAC evaluation revealed
The Commission’s June 2025 evaluation of DAC1–DAC6 concluded that the framework materially strengthened Member States’ capacity to fight tax fraud, evasion and avoidance, generating estimated net benefits of about €6.8 billion per year. At the same time, the review highlighted rising complexity, fragmented implementation, and persistent data-quality and compliance frictions, which weaken the effectiveness of automatic exchange when information is incomplete or poorly standardised.
Where reforms may bite: Pillar Two overlaps and DAC6 proportionality
A key practical theme is overlapping obligations, especially where Pillar Two-related processes can trigger parallel notifications and exchanges through different DAC layers. DAC6 remains another pressure point: policymakers want to preserve meaningful signals about aggressive cross-border arrangements, while the market continues to push back against over-reporting driven by broad hallmarks and inconsistent interpretation. Alongside legal streamlining, the Commission’s consultation highlights taxpayer identification and IT interoperability, reflecting an increasingly technical reality: enforcement often fails not on legal grounds, but on mismatched identifiers and incompatible datasets.
OECD focus: taxing globally mobile individuals
In parallel, the OECD has been collecting stakeholder input on the tax challenges created by modern mobility, including remote work, short-term assignments and highly mobile professionals. The underlying tension is that residence tests, day-count thresholds and employer withholding concepts were built for a far more static labour market. In today’s cross-border workflows, the same facts can trigger uncertainty, double taxation risk, and disproportionate compliance—especially when tax, social security and immigration rules are not aligned.
BEPS Action 5: tax rulings transparency keeps expanding
The OECD also released the ninth annual peer review report under BEPS Action 5 on the spontaneous exchange of information on tax rulings. The report underscores how large the system has become and why it matters: more jurisdictions, more in-scope rulings, and more exchanges—plus recommendations where domestic processes and timeliness still lag. For multinationals and cross-border investors, the direction is clear: the space for opaque rulings practices is shrinking, and the probability that structures become visible through official channels keeps rising.
CRS and CARF: transparency moves into tokenised and crypto assets
Another major trend is the expansion of tax transparency into digital finance. OECD updates to CRS and the Crypto-Asset Reporting Framework guidance increasingly address tokenised assets, stablecoins and operational questions around crypto-asset service providers, helping jurisdictions converge on classification and reporting. In practice, this pushes compliance expectations beyond traditional bank accounts toward end-to-end data trails in digital asset ecosystems, where misclassification and weak taxpayer identification can quickly create multi-jurisdictional exposure.
What this means for investors and businesses
The 2026 story is not just “more reporting,” but more automated, more standardised, and less forgiving reporting. Companies will increasingly need clean group-wide data architecture, consistent taxpayer identifiers, and a clear mapping of where obligations overlap. For individuals—especially those splitting time between countries—the practical priority is documenting residence positions, tracking days, and formalising remote-work arrangements, because information exchange is making these facts easier for authorities to verify.
As International Investment experts report, the DAC recast debate and the OECD’s parallel upgrades point to a single direction: tax transparency is becoming digital, interoperable and global, and the best outcomes in 2026 will belong to those who align structures, data, and residence positions early—before enforcement catches up.
Подсказки: DAC, DAC6, Pillar Two, BEPS Action 5, tax rulings, CRS, CARF, tax transparency, tax residence, remote work, European Commission, OECD