FASTER – Council Directive on faster and safer relief of excess withholding taxes

FASTER (Directive 2025/50/EU) is an EU directive to harmonise and accelerate procedures for the relief of excess withholding taxes on dividends and interest from listed securities. It addresses the problems caused by fragmented, slow and abuse-prone national withholding tax refund systems.

• Digital EU Tax Residence Certificate (eTRC): A unified, digitally issued residence certificate recognised in all member states.
• Fast-track procedure: Standardised fast-track relief procedure (relief at source or quick refund) alongside the regular refund process.
• Certified Financial Intermediaries (CFI): Financial institutions may be certified as trusted intermediaries and manage applications on behalf of their clients.
• Compliance and anti-abuse: Harmonised due diligence obligations to prevent Cum-Ex and similar withholding tax abuse.

The fragmentation of withholding tax refund systems in the EU causes, according to the European Commission, estimated annual efficiency losses of EUR 8.4 billion and facilitates tax abuse (in particular Cum-Ex schemes). The European Commission proposed FASTER on 19 June 2023 as part of its tax package. After intensive negotiations in the Council, Directive 2025/50/EU was adopted on 10 December 2024 and published in the EU Official Journal on 10 January 2025. The directive entered into force on 30 January 2025.

Member states must transpose the directive by 31 December 2028; the new procedures apply from 1 January 2030.

FASTER applies to withholding tax relief on dividends from listed shares and on interest from listed bonds subject to withholding tax in an EU member state. Obligated parties are both member states (regarding the design of their procedures) and certified financial intermediaries. Not covered are withholding taxes on royalties, refunds in the context of corporate transactions, and purely domestic situations.

• Introduction of a digital EU Tax Residence Certificate (eTRC) by all member states by 2030.
• Provision of at least one standardised fast-track procedure (relief at source or quick refund) for eligible investors.
• Establishment of a national registration system for Certified Financial Intermediaries (CFI).
• Performance of due diligence by CFIs to verify eligibility and prevent abuse.
• Reporting of dividend and interest payment information by CFIs to tax authorities (to facilitate oversight).

3 corrections:
- Incorrect adoption date: Directive was adopted on 10 December 2024, not 14 January 2025
- Commission proposal date: 19 June 2023 confirmed, but history text says only 'June 2023'
- Official directive title is incomplete: 'Council' missing and wording differs from official text
2 updates:
- Missing key_dates: OJ publication (10 Jan 2025) and entry into force (30 Jan 2025)
- Missing EP involvement in key_dates timeline
3 clarifications.