DAC7: the new digital-platform reporting affecting your business in 2026

7 forces Amazon. If you sell on Amazon, Etsy, Airbnb, Vinted or any European marketplace, DAC7 forces the platform to report your income to your tax authority. We explain how it works and how to plan.

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 US LLC operating on these platforms as a seller, it does too.

CRS 2.0, CARF and DAC8 update (OECD package)

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: OECD — CRS, OECD — CARF, EUR-Lex — Directive (EU) 2023/2226 (DAC8).

The takeaway to remember is the same as always: the United States stays outside the CRS perimeter by architecture, not by opacity. Washington runs its own regime (FATCA), did not sign CRS 1.0 and will not sign CRS 2.0 — which is exactly why your US LLC remains a fully declarable structure in your country of residence. We unpack the full picture in CRS 2.0 and CARF: why the US will never sign and what it means for your LLC.

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.

It is not a rule "for big sellers only": the de minimis threshold is very low (sellers with fewer than 30 sales of goods and less than €2,000 of consideration per year may be excluded from platform reporting, but not from personal 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:

The platform identifies your LLC as seller.
Collects LLC data (EIN, US registered address, operational address) and beneficial-owner data if the platform follows strict KYC criteria.
Reports gross quarterly income generated through the platform to the tax authority of the platform's country.
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 CRS for residents in Spain and LATAM.
DAC6: mandatory disclosure of cross-border arrangements by tax intermediaries.
DAC7: digital-platform reporting (above).
DAC8: crypto-asset reporting, fully applicable from today. See DAC8 and crypto.
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

Your IRPF and VAT must match the DAC7 report. If Amazon reports €60,000 of gross income in FY 2025 linked to your beneficial-owner status and you declare €0, the AEAT will almost certainly open a file.
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).
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 LLCs (see BOE Feb-2020 and DGT/TEAC doctrine on LLC) treats this income as imputable to the partner.
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.

How to plan correctly

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.
Optimize within the law. There is LLC expense deductibility (see LLC tax deductions) and remittance planning to the partner.
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 designing a solid international structure.
Don't ignore the first notice. Tax authorities usually send "discrepancy" communications before formal audit; responding well prevents proceedings. Relax: at Exentax this is what we do every week, we close it before the letter ever lands in your inbox.

In summary

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 free consultation.

Tax compliance in your country: CFC, controlled-foreign rules and income attribution

A US LLC is a fully legal, internationally recognized vehicle. But compliance does not end at incorporation: as an owner who is tax-resident elsewhere, your local tax authority still has the right to tax what the LLC earns. The key is under which regime.

By jurisdiction

Spain (LIRPF/LIS). An operative single-member disregarded LLC (real services, no significant passive income) is generally treated under income attribution (art. 87 LIRPF): the LLC's net profits are attributed to the member in the year they arise and integrated into the general IRPF base. If instead the LLC elects corporation treatment (Form 8832) and is controlled by a Spanish resident with mostly passive income, the CFC regime (art. 91 LIRPF for individuals, art. 100 LIS for companies) can apply. The choice is not optional: it depends on economic substance, not on the label.
Information returns. US bank accounts with average or year-end balance >€50,000: Form 720 (Law 5/2022 after CJEU C-788/19, 27/01/2022, penalties now under the general LGT regime). Related-party transactions and dividend repatriation: Form 232. US-custodied crypto: Form 721. That is exactly why at Exentax we keep your calendar tight — you stop thinking about deadlines and we close them before they ever bite.
Spain–US tax treaty. The treaty (BOE 22/12/1990, Protocol in force 27/11/2019) governs double taxation on dividends, interest and royalties. An LLC without a permanent establishment in Spain does not by itself create a PE for the member, but effective management can if all activity is run from Spanish territory.
Mexico, Colombia, Argentina and other LATAM jurisdictions. Each has its own CFC regime (Mexico: Refipres; Argentina: foreign passive income; Chile: art. 41 G LIR). Common principle: profits retained inside the LLC are deemed received by the member if the entity is treated as transparent or controlled.

How to read DAC7 as a stable property of the platform reporting stack rather than as a recurring surprise

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.

How to read DAC7 platform reporting as a stable yearly mapping rather than as a recurring concern

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.

Before going further, put numbers on your case: the Exentax calculator compares, in under 2 minutes, your current tax bill with what you would carry running a US LLC properly declared in your country of residence.

> Free consultation, no strings attached

Practical rule: an operative LLC with substance, properly declared in your country of residence, is legitimate tax planning. An LLC used to hide income, fake non-residence or shift passive income with no economic justification falls within art. 15 LGT (anti-abuse) or, worse, art. 16 LGT (simulation). The facts decide, not the paperwork.

At Exentax we structure the entity to fit the first scenario and document every step so your local return can be defended in case of review.

Banking and tax facts worth clarifying

Fintech and CRS information evolves; here is the current state:

Notes by provider

Mercury operates with several federally chartered partner banks and FDIC coverage via sweep network: mainly Choice Financial Group and Evolve Bank & Trust, with Column N.A. still in some legacy accounts. Mercury is not itself a bank; it is a fintech platform backed by those partner banks. If Mercury closes an account, the balance is typically returned by paper check mailed to the account holder's registered address, which can be a serious operational problem for non-residents; keep a secondary account (Relay, Wise Business, etc.) as contingency.
Wise ships two clearly different products: Wise Personal and Wise Business. For an LLC you must open Wise Business, not the personal account. Important CRS nuance: a Wise Business held by a US LLC sits outside CRS because the account holder is a US entity and the US is not a CRS participant; the USD side operates via Wise US Inc. (FATCA perimeter, not CRS). In contrast, a Wise Personal opened by an individual tax-resident in Spain or another CRS jurisdiction does trigger CRS reporting via Wise Europe SA (Belgium) on that individual. Opening Wise for your LLC does not bring you into CRS through the LLC; a separate Wise Personal in your own name as a CRS-resident individual does report.
Wallester (Estonia) is a European financial entity with an EMI/issuing-bank licence. Its European IBAN accounts are within the Common Reporting Standard (CRS) and therefore trigger automatic reporting to the tax administration of the holder's country of residence.
Payoneer operates through European entities (Payoneer Europe Ltd, Ireland) that are also in scope for CRS for clients resident in participating jurisdictions.
Revolut Business: when paired with a US LLC, it operates under Revolut Technologies Inc. with Lead Bank as its US banking partner. The account delivered is a US account (routing + account number); no European IBAN is issued to a US LLC. The European IBANs (Lithuanian, Belgian) belong to Revolut Bank UAB and are issued to European clients of the group. If you are offered a European IBAN tied to your LLC, confirm exactly which legal entity holds that account and which regime it reports under.
Zero tax: no LLC structure delivers "zero tax" if you live in a country with CFC/tax transparency or income attribution rules. What you achieve is no double taxation and correct reporting at residence, not elimination.

We set it up without you losing a weekend

Thousands of freelancers and entrepreneurs already operate their US LLC fully legally and properly documented. At Exentax we handle the entire process: formation, banking, payment gateways, bookkeeping, IRS filings and compliance in your country of residence. Book a free consultation and we will tell you honestly whether the LLC makes sense for your case, with no absolute promises.

How DAC7 fits the operational reality of a digital seller

DAC7 obliges EU digital platforms to report to the tax authorities of each Member State the information of their active sellers: identity, compensation collected, commissions retained and tax residency country. Information is transmitted in January of each year, referring to the closed financial year. This is what changes in practice for anyone selling online, with or without LLC.

Who is in and who is out. Anyone with over 30 transactions a year or over 2,000 € of annual compensation on a covered platform. Below both thresholds, the seller stays "occasional" and is not reported. Above either, you enter the automatic flow.
Covered platforms. Amazon, eBay, Etsy, Vinted, Wallapop, Airbnb, Booking, Uber, Cabify, Glovo, Just Eat and similar. Also SaaS marketplace platforms (creator platforms, p2p, private car rental). Excluded are pure professional services platforms not processing payments on the seller's name (Upwork is in; LinkedIn is out).
US LLC as seller. If you sell via US LLC on Amazon UK or Etsy DE, the platform reports your LLC to the Member State authority where the platform is established (typically Luxembourg or Ireland). The report then travels to the seller's declared tax residency country. If the declared address is the US provider's, the report goes to the US (no real fiscal use); if it is your personal residency address, it goes to that country.
Implication for the Spanish tax authority. AEAT receives data in February each year and automatically crosses it with the IRPF and, if applicable, VAT filing. Omitting income from DAC7 platforms is already the most frequent cause of parallel assessments on digital profiles for recent years.

What we are asked the most

How do I avoid the platform reporting my LLC poorly? By ensuring the declared business address and TIN match the right jurisdiction. An LLC with the provider's Wyoming address but a Spain-resident owner generates a report to the US, not to Spain; that puts you "out" of the automatic cross but still obliges you to declare income at residency.

If I cross the thresholds, what duty do I have? The ones you already had: declare income at IRPF as business income or capital gain as applicable and, if relevant, register with RETA or an alternative structure. DAC7 does not create new duties - it makes existing ones visible.

At Exentax we tune your LLC configuration on each DAC7 platform so the report is consistent, fit the income into your IRPF/VAT and leave you safe from parallel assessments due to mismatches.

How we work at Exentax

Our team specialises in international tax structures for residents of Spanish-speaking countries operating online businesses. We combine local knowledge of Spain, Andorra and Latin America with operational experience setting up entities in Delaware, Wyoming, Estonia and other jurisdictions. Every case starts with a free consultation in which we evaluate residency, activity and goals, and we honestly tell you whether the proposed structure makes sense or whether a simpler alternative is enough.

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.

On the same topic

What if HMRC, the IRS or my local tax authority asks about my LLC?

It's the question every client raises in the first consultation, and the short answer is: your LLC isn't opaque, and a properly declared structure closes any inquiry in standard forms. Your tax authority can request the state Certificate of Formation (Wyoming, Delaware or New Mexico), the EIN issued by the IRS, the signed Operating Agreement, the Mercury or Wise statements for the year, the Form 5472 plus pro-forma 1120 you filed, and the bookkeeping that reconciles income, expenses and movements. If all of that exists and is delivered in order, the inquiry doesn't escalate.

What tax authorities do pursue, and rightly, is sham ownership (nominees, paper residency) and undeclared foreign accounts. A well-structured LLC is the opposite: you appear as beneficial owner in the BOI Report when applicable (verifiable at fincen.gov/boi), you sign the bank accounts and you declare the income where you actually live. The structure is registered with the state Secretary of State, with the IRS and, when European banks are involved, inside the CRS perimeter of the OECD standard.

The mistake that really sinks an inquiry isn't having an LLC; it's not attributing the income correctly in your domestic return, not declaring foreign accounts when the year-end balance exceeds the local threshold (€50,000 in Spain via Modelo 720; the equivalent FBAR / Form 8938 in the US for residents; T1135 in Canada), and not documenting related-party transactions between the member and the LLC. Those three fronts are worth closing before any request arrives, not after.

## What an LLC does NOT do

- It does not exempt you from tax in your country of residence. If you live in Spain, France, Germany or Portugal, you are taxed there on worldwide income. The LLC organises your US side (zero federal tax for non-resident SMLLC pass-through, absent Effectively Connected Income); it does not switch off your domestic taxation. The income tax is computed on the attributed profit, not on the dividends actually paid.

- It is not an offshore vehicle or a BEPS scheme. It is a US entity recognised by the IRS, registered in a specific state with physical address, registered agent and annual informational filings. Classic offshore jurisdictions (BVI, Belize, Seychelles) leave no public trace; an LLC leaves a trace in five different places.

- It does not protect you if you commingle funds. The pierce the corporate veil doctrine kicks in as soon as a judge sees the LLC and the member behaving as the same wallet: mixed accounts, personal expenses paid from the LLC, no signed Operating Agreement, no bookkeeping. Three suspicious transactions are enough.

- It does not save you social security contributions at home. If you are self-employed in Spain, France or Germany, your monthly social contribution remains identical. The LLC handles the trading side with international clients; your personal contribution is independent.

- It does not exempt you from declaring foreign accounts. Spain residents file Modelo 720 / 721; UK residents, the SA106; Portugal residents, the Anexo J of Modelo 3 IRS; Germany residents, the Anlage AUS. Those obligations belong to the individual, not to the LLC.

At Exentax we cover those five fronts every year alongside the US federal calendar (Form 5472, pro-forma 1120, FBAR, state Annual Report and BOI Report when applicable). The goal is that no inquiry finds a loose end and that the structure withstands a 5-to-7-year retroactive review.

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