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ALFI welcomes the public consultation on the proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes released on 19 June 2023 and introducing a new EU system for the avoidance of double taxation and prevention of tax abuse in the field of withholding taxes (the draft Directive).
ALFI strongly supports the initiative of the European Commission to improving withholding tax relief and refund procedures and is pleased to hereby provide its views on the draft Directive. ALFI has always been in favour of introducing rules which are as harmonised as possible at EU level and which would eliminate the legal uncertainties surrounding the procedures for relief at source or refund of excess withholding tax paid.
ALFI calls for a common and broad application of the Directive for a Faster and Safer Relief of Excess Withholding Taxes. ALFI however believes that this Directive can effectively enable end investors, including in UCITS and Alternative Investment Funds (as defined by the UCITS Directive and the AIFMD) to have access to withholding tax relief and/or quick refund systems as suggested, provided that it is supported by effective and clear implementation rules and guidelines (including, where relevant, taxonomies and data definitions) on the aspects described in the comments below.... more at full paper