Memo #
34206

Submissions to European Commission on Improving Withholding Tax Procedures
| Print

[34206]

June 30, 2022

TO: ICI Members
ICI Global Members
Global Tax Committee
Tax Committee SUBJECTS: International/Global
Tax RE: Submissions to European Commission on Improving Withholding Tax Procedures

 

ICI made the attached submission (survey response and letter) and joined a coalition letter with other industry associations in response to a public consultation regarding an initiative to develop an EU-wide withholding tax regime. The initiative's aim is to facilitate cross-border investment and to prevent tax abuse by making withholding tax relief procedures on dividend and/or interest payments for non-resident investors more efficient and by increasing the ability of tax administrations to exchange information.

To inform ICI's responses, we surveyed members to better understand the scope of cross-border withholding tax difficulties.[1] ICI also commented last fall on an earlier phase of this initiative.[2]

ICI's submission urges:

  • a comprehensive solution that addresses fully governments' concerns about tax
    abuse while ensuring that investors receive treaty-provided withholding tax rate
    reductions;
  • incremental improvements, while a comprehensive solution is developed, that
    harmonize investor self-certifications, treaty claim forms, and information reporting
    schemas;
  • reliance on electronic, rather than paper, records and delivery mechanisms;
  • at-source withholding tax relief, with quick refund procedures available in the
    (preferably limited) situations in which at-source relief cannot be provided; and
  • guidance clarifying and confirming the treaty eligibility of CIVs and their investors.

 

 

 

Katie Sunderland
Assistant General Counsel
 

 

endnotes

[1] See ICI Memorandum No. 34182, dated June 15, 2022.

[2] See ICI Memorandum No. 33862, dated October 26, 2021.

    Attachments

    34206a.pdf
    34206b.pdf
    34206c.pdf