DAC7 and LLC: platforms report, your structure must be ready

Amazon, Etsy, Airbnb and EU marketplaces report seller income. A US LLC still works when invoicing, banking and local tax are designed as one structure.

DAC7 is one of the most important regulations of the last few years for anyone selling through European digital platforms, and it's probably the most ignored one today. If you sell on Amazon, Etsy, eBay, Vinted, Airbnb, Booking, Uber, Cabify, Wallapop or any European marketplace, it affects you. And if you have a <a href="/en/blog/us-llc-for-non-residents-tax-structure">US LLC</a> operating on these platforms as a seller, it does too.

CRS 2.0, CARF and DAC8 for DAC7 and LLC

DAC7 has covered the reporting of digital platforms (Airbnb, Vinted, Etsy, Amazon, Wallapop) toward European tax authorities since it took effect; with DAC8 entering into force on 1 January 2026 over crypto-assets and the revised CRS 2.0, the OECD package closes the digital loop and locks the full picture of what your tax authority receives automatically each year.

The OECD adopted an integrated package combining CRS 2.0 (the revised Common Reporting Standard, which brings EMIs and specified electronic-money products into the perimeter and tightens due diligence on controlling persons) and CARF (the Crypto-Asset Reporting Framework, which extends automatic exchange to crypto exchanges, custodians and crypto-derivative platforms). The European Union transposed it through Directive (EU) 2023/2226 (DAC8), adopted on 17 October 2023, which amends Directive 2011/16/EU to incorporate both components. The substantive application date is 1 January 2026 and the first effective exchange lands in January 2027, on 2026 reporting-year data.

Official sources: <a href="https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/" target="_blank" rel="noopener nofollow">OECD — CRS</a>, <a href="https://www.oecd.org/tax/exchange-of-tax-information/crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.htm" target="_blank" rel="noopener nofollow">OECD — CARF</a>, <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023L2226" target="_blank" rel="noopener nofollow">EUR-Lex — Directive (EU) 2023/2226 (DAC8)</a>.

DAC7 is platform reporting, not a generic bank-account rule. Marketplaces, gig platforms, rental platforms and payment intermediaries can report seller information even when the business also uses a US LLC or US banking. The correct analysis separates platform data, bank data and the owner's residence obligations. We unpack the broader privacy layer in <a href="/en/blog/crs-carf-and-us-banking-privacy-for-llc-owners">CRS, CARF and US banking privacy for your LLC</a>.

What DAC7 is

DAC7 is the sixth amendment to Council Directive 2011/16/EU on administrative cooperation in tax matters (DAC). Formally: Council Directive (EU) 2021/514 of 22 March 2021. It establishes the obligation for digital platforms (platform operators) to identify their active sellers, collect information about their income and report that data annually to the tax authority of the Member State where the platform is registered or has its place of effective management.

That tax authority then automatically shares the information with the tax authorities of the other Member States where the sellers reside. And, through bilateral or multilateral agreements, also with authorities in third countries.

Spain transposed DAC7 via Law 13/2023 of 24 May (amendment to the General Tax Law) and Royal Decree 117/2024 of 30 January, which regulate the new informational obligation of digital-platform operators and create Form 238.

Who is affected

DAC7 affects:

• Digital platforms facilitating a "relevant activity": sale of goods, personal services, rental of immovable property, rental of any mode of transport. It includes EU-resident platforms and foreign platforms operating in the EU.
• Sellers using these platforms, both individuals and entities, residing anywhere in the world when selling to EU users or when the platform is in the EU.

This is not a rule "for big sellers only": a seller of goods may be excluded from platform reporting only where the platform facilitated fewer than 30 sales and the total consideration paid or credited did not exceed EUR 2,000 during the reporting period. That DAC7 exclusion does not remove the seller's own tax obligations.

What is reported

For each seller, the platform reports annually:

The detail is quarterly, allowing tax authorities to cross-check VAT and income-tax filings with high precision.

Schedule

• 1 January 2023: effective application across the EU.
• 31 January 2024: first annual report on FY2023.
• Recurring annual reporting since then. Spain: Form 238, first filed in January 2024 on FY 2023 data.
• today (now): fourth year of full application. Tax authorities have a three-year history of cross-checkable data. Resulting audits begin to materialize.

How it affects an LLC owner

If your LLC sells on Amazon Europe (Amazon EU SARL, Luxembourg) or Etsy (Etsy Ireland UC, Ireland) or any European platform:

1. The platform identifies your LLC as seller.
2. Collects LLC data (EIN, US registered address, operational address) and beneficial-owner data if the platform follows strict KYC criteria.
3. Reports gross quarterly income generated through the platform to the tax authority of the platform's country.
4. That authority forwards to the tax authority of the seller's country of residence: if the LLC is registered in the US, the data is not automatically forwarded since the US is not an EU Member State; but if the beneficial owners are EU residents, data on them is forwarded to their Member State of residence.

This complements the CRS reporting from banks receiving platform payments. The DAC7 + CRS combination leaves very little opacity.

Combination with CRS, DAC8 and FATCA

DAC7 does not operate in isolation. It's part of a regulatory ecosystem:

• CRS / DAC2: bank reporting of balances and income. See <a href="/en/blog/crs-in-spain-and-latam-120-countries-since-2017">CRS for residents in Spain and LATAM</a>.
• DAC6: mandatory disclosure of cross-border arrangements by tax intermediaries.
• DAC7: digital-platform reporting (above).
• DAC8: crypto-asset reporting, fully applicable from today. See <a href="/en/blog/dac8-crypto-and-llc-eu-reporting-under-control">DAC8 and crypto</a>.
• FATCA (US): reporting of US-person accounts at foreign institutions.

If your LLC sells on Amazon Europe, collects in Wise Belgium, pays European suppliers and you reside in Spain: DAC7 + CRS + DAC8 (if crypto) generate a three-dimensional crossed tax profile that's hard to evade.

Practical implications

1. Your IRPF and VAT must match the DAC7 report. If Amazon reports €60,000 of gross income for the 2025 fiscal year linked to your beneficial-owner status and you declare €0, the AEAT will almost certainly open a file.
2. VAT regime. Selling on Amazon Europe from a US LLC obliges you to evaluate your EU VAT registration obligation, OSS/IOSS, Marketplace Facilitator (Amazon withholds VAT in many cases as deemed supplier).
3. LLC taxation. The DAC7 report evidences income; your LLC, as Disregarded Entity, passes those revenues to you, and you declare them where you reside. Spanish doctrine on LLC (see <a href="/en/blog/dgt-teac-and-feb-2020-boe-doctrine-on-the-us-llc">BOE Feb-2020 and DGT/TEAC doctrine on LLC</a>) treats this income as imputable to the partner.
4. Risk of simulation. If you interpose an LLC without substance to sell on Amazon Europe while being Spanish resident, the AEAT can treat the operation as simulation and attribute income directly to the resident individual.

Affected platforms (non-exhaustive)

• E-commerce of goods: Amazon, eBay, Etsy, AliExpress EU, Vinted, Wallapop, ManoMano.
• Personal services: Fiverr (EU entity), Upwork (EU entity), TaskRabbit, Glovo, Just Eat, Deliveroo.
• Property rental: Airbnb, Booking, Vrbo, Spotahome.
• Mobility: Uber, Cabify, Bolt, Free Now.

Report income on the same basis as the platform

1. Declare income coherently. If you sell on Amazon Europe, those revenues are cross-checked with your IRPF (Spanish, Mexican or Argentinean) via DAC7 + CRS data. The only valid strategy is to declare correctly.
2. Optimize within the law. There is LLC expense deductibility (see <a href="/en/blog/run-your-llc-day-to-day-without-irs-chaos">LLC tax deductions</a>) and remittance planning to the partner.
3. Consider substance. If you'll operate at scale through an LLC, give it substance (office, contracts, real operational presence) or accept that the AEAT can look at it under transparency/simulation criteria. Full framework in <a href="/en/blog/international-tax-design-3-jurisdictions-max-no-cfc">designing a solid international structure</a>.
4. Don't ignore the first notice. Tax authorities usually send "discrepancy" communications before formal audit; responding well prevents proceedings. Exentax gives the obligation a named owner, a due date and supporting evidence.

Match platform data to the taxpayer first

DAC7 is the natural complement of CRS for the platform economy. It is not optional, cannot be avoided, and combined with CRS and DAC8 forms the densest tax-information system in European history. The professional way to operate is to declare correctly and design the structure so what is declared is tax-efficient.

Sell on Amazon, Etsy, Airbnb or any European platform from an LLC and want to see how to legally optimize your tax burden without risk? book your strategic review.

Reconcile platform reports before filing

DAC7 reads more calmly when it's treated as a stable property of the platform reporting stack rather than as a recurring surprise. The DAC7 standard defines who reports what to whom in a perimeter that doesn't change every year, and understanding the perimeter once is enough to anchor the annual exposure without repeating the analysis.

How to capture the DAC7 perimeter in a short written note

The DAC7 perimeter captures more durably in a short, dated note that lists the reporting platform, the seller category and the year of first report. This note becomes the reference whenever any of the three values shifts in a later period.

Operating checkpoint: DAC7 and LLC

DAC7 platform reporting reads more usefully when it's treated as a stable yearly mapping between the platform that hosted the activity, the country of residence of the seller and the threshold that triggered the report, than as a recurring concern. The mapping doesn't change year to year — only the volume on each platform moves, and a short dated note in the personal folder with the three axes makes the position reviewable in a few minutes during a tax conversation.

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For DAC7, the platform report is not the full tax analysis. The important question is whether the reported seller, payout account, contracting entity and tax residence match the structure the founder is using.

How Exentax prepares marketplace income before DAC7 reports

For platform reporting, Exentax reviews the platform, seller identity, payout account, tax residence, VAT profile and annual reporting perimeter together. DAC7 is not solved by changing an entity label; the seller file has to explain who earned the income and where it belongs.

Reading the DAC7 calendar without anxiety

DAC7 looks intimidating from the outside, but it operates on a

predictable annual rhythm. Platforms collect identifying data

during the calendar year, run their own internal validation

during the early weeks of the following year, and submit the

consolidated report to the relevant tax authority by the

deadline set by each member state — typically January 31. The

tax authority then exchanges the data with the other relevant

jurisdictions during the following months.

For the LLC member, the practical implication is straightforward:

the figures that the platforms hold today are the figures that

will land on the tax administration's desk a few months later.

A short quarterly review with the advisor — checking that the

platform-side data matches the bookkeeping — keeps any

inconsistency manageable while it is still trivial to correct.