DACSI has submitted a consolidated industry review to the European Commission on the FASTER Activity Reports concerning the Registered Owner Declaration and indirect investment structures.
DACSI supports FASTER’s objective of establishing harmonised and efficient procedures for relief at source and quick refunds. However, several legal, operational and technical issues should be resolved before the process model and technical specifications are finalised.
Key recommendations include proportionate and risk-based responsibilities for Certified Financial Intermediaries, a declaration validity period of at least three years, workable arrangements for retail investors and investment funds, and clarity on the definition of “final investor”. The framework should also support partial and mixed-entitlement claims while avoiding unnecessary collection of investor data.
DACSI calls for the complete end-to-end process to be agreed and tested before the technical specifications are frozen.
Read the full DACSI Review of FASTER Articles 12 and 15.