Acupay Supports Changes Introduced to German Withholding Tax Reclaims

On January 1st 2023, Germany introduced a new electronic filing procedure to apply for withholding tax (WHT) exemption certification and reclaim excess WHT from the German Federal Tax Office (Bundeszentralamt für Steuern, or BZSt for short). This electronic filing procedure has replaced the previous system where applications had to be filed via hardcopy paper applications and is mandatory for all applications filed after 31 December 2022.

The electronic filing procedure requires the applicant (or its representative) to register with the Federal Tax Office portal (BZSt online portal) beforehand, where all required information and supporting documentation must be uploaded.

Please note that Acupay has duly registered as a user of the BZSt online portal so that we can continue to support clients by processing German WHT reclaims through the portal on the client’s behalf.

General Information

Germany generally does not apply WHT on interest, but a 26.375% WHT applies on dividends. To benefit from a reduced WHT rate under an applicable double tax treaty (DTT) or an EU directive, a request for a refund would need to be submitted.

There is no longer a requirement to have the tax residency of the applicant certified by the relevant tax authorities on the application form itself. Rather, an applicant may submit a tax residency certificate issued by the relevant tax authorities on the portal. The applicant (or their representative) applying for the refund must submit all required supporting documentation on the new electronic portal.

Current Requirements

To act as representative and submit a German tax reclaim request on your behalf, the following supporting information and documentation will be required:

• Information on applicant and requested tax reclaim details including bank details;

• Certificate of Tax Residence issued by the relevant tax authorities (e.g., IRS Form 6166 for US beneficial owners);

• The original tax voucher issued by the last domestic paying agent;

• In cases where a refund needs to be given to a person other than the applicant, an original document issued by the applicant authorizing the document holder must be submitted to collect the refund (e.g., Power of Attorney).

* Please note that this list is for indicative purposes only. Document requirements subject to change based on beneficial investor type and country of tax residence.

Contact our Operations team to learn more about our Acupay’s Germany WHT tax reclaim services.