Faster and Safer Tax Excess Relief

EESC opinion: Faster and Safer Tax Excess Relief

Key points

The EESC:

  • supports the Commission's objective of avoiding double taxation and complicated procedures for reduced rates to the detriment of investors holding securities in a transnational context. Faster and more efficient procedures will support cross-border investments in the interest of the internal market;
  • appreciates the added value that the Commission proposal could bring in order to support cross-border investments across the EU, especially for retail investors, by achieving substantial procedural simplification;
  • welcomes the introduction of the eTRC, a uniform, EU-wide electronic tax residence certificate that will improve the timing of refunds and so benefit transnational investors. The EESC suggests that the eTRC might be used to simplify issues in addition to those already covered in the Proposal;
  • underlines that the Commission expects the proposal to deliver significant cost savings compared to the status quo and encourages the Commission to periodically verify whether such savings are actually achieved;
  • agrees with the Commission's choice to establish a de minimis threshold, whereby investors with dividend payments below a threshold of EUR 1000 are not asked to provide information about financial arrangements or minimum holding periods. This choice seems to strike a balance between the effectiveness of the new rules for the benefit of the internal market and investors, and the need for simplification by avoiding excessively burdensome duties on small amounts of securities held;
  • encourages Member States to swiftly provide the Commission, during the implementation period, with annual reports on statistics regarding how many excess WHT reclaims are refunded/relieved both within and after the timeframe in order to ensure that WHT reclaims are gradually refunded/relieved within the ambitious timeframe of no more than 25 days set by the Commission proposal.