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REPORT (09925/2024 – C100002/2024 – 2023/0187(CNS))

On the draft Council directive on Faster and Safer Relief of Excess Withholding Taxes

A-10-2024-0011

Committee on Economic and Monetary Affairs · Rapporteur: Herbert Dorfmann

✦ In short · AI summary of this text, generated 4 Sept 2026

Written by a language model from the full text only; every figure comes from the text. The paragraph links open the paragraph a statement rests on — check the text itself before relying on it.

Parliament approves the Council draft directive on Faster and Safer Relief of Excess Withholding Taxes, which introduces a common EU digital tax residence certificate and two fast-track procedures for tax relief. The directive exempts member states with comprehensive relief-at-source systems and small financial markets, and extends the entry into force to 1 January 2030.

Committee position. The rapporteur proposes that Parliament approves the proposal without amendments pursuant to a simplified procedure.

Key points

  1. Parliament approves the Council draft without amendments.
  2. The directive introduces a common EU digital tax residence certificate (eTRC) and two fast-track procedures complementing the standard refund procedure.
  3. Deadlines for eTRC issuance and quick refund are prolonged, making relief less fast than originally proposed.
  4. Member states with comprehensive relief-at-source systems and market capitalisation ratio below 1.5% are exempt.
  5. Financial intermediaries must register in national registers to request fast-track procedures; a European Certified Financial Intermediary Portal is created.
  6. Entry into force is extended from 1 January 2027 to 1 January 2030.

Who is affected

  • Member states with comprehensive relief-at-source systems and small financial markets are exempt from certain obligations.
  • Financial intermediaries must register in national registers to use fast-track procedures.

Figures and deadlines

  • 1.5% market capitalisation ratio threshold for exemption.
  • 1 January 2030 entry into force.

Legal basis: Article 115 of the Treaty on the Functioning of the European Union