On January 30, 2025, the Council Directive (EU) 2025/50 on Faster and Safer Relief of Excess Withholding Taxes (FASTER Directive) enters into force, twenty days after its publication.
IMPLEMENTATION TIMELINE
Member States are required to transpose the FASTER Directive into their national legislation by December 31, 2028, with the new rules set to become applicable from January 1, 2030.
KEY FEATURES OF THE FASTER DIRECTIVE
The directive aims to streamline and enhance the efficiency of tax relief processes across the EU by introducing:
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A Common EU Digital Tax Residence Certificate – Standardized across all Member States, ensuring uniform content and ease of verification.
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Fast-Track Procedures for Tax Refunds – Two alternative systems will complement existing standard refund mechanisms:
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Relief at Source System – Allows for reduced withholding tax rates directly at the point of payment.
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Quick Refund System – Ensures the rapid reimbursement of excess withholding taxes.
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Member States must implement at least one of these systems or a combination of both.
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National Registers for Financial Intermediaries – Designed to facilitate the fast-track procedures, financial intermediaries listed in these registers will be subject to enhanced due diligence and standardized reporting requirements.
FINAL ADOPTION AND NEXT STEPS
The adoption of the FASTER Directive marks the final step in the legislative process. With its publication in the Official Journal of the EU, Member States must now begin the transposition process to ensure compliance by the 2030 implementation deadline.
