Germany - Additional Submission Check Added Related to Beneficial Owner Data

Please be advised that, starting on November 6, 2017, the Acupay System will perform a check comparing the beneficial owner submission data to the DTV filer’s beneficial owner data on file with the German tax authority (the “BZSt”) and Acupay.

To provide background information for those who are not aware: when a German ADR/ORD reclaim is submitted using the BZSt’s electronic submission process (the “DTV”), the BZSt assigns a unique number (the “BZSt Kennnummer” or “DTV BO Code”) to each beneficial owner based on their tax identification number, name, entity type, and country of residence. From that point forward, any submission for the same beneficial owner will be checked against the previously submitted details based on this unique DTV BO Code. Any variation or discrepancy in the submitted beneficial owner details may lead to additional (manual) audits or reclaim rejection. In extraordinary circumstances, it could also lead to the BZSt excluding participants from being able to use the DTV process if they are under the impression that the beneficial owner details are not being entered correctly due to gross negligence or possible deception.

In order to try to support you in maintaining record accuracy and consistency, we’ve implemented an additional check at the submission level. Starting November 6, 2017, if there is a potential discrepancy between the submission data and the data on file when you submit for German ADR/ORD reclaims using the Acupay System, the system will inform you of the differences and highlight the affected fields in bold red text. You’ll be able to review this information by selecting “Click to view my records” and then “Review Discrepancies” (see red boxes in images below).

The authorized representative has to then select the correct record(s). If the data on file is correct, simply tick the correct option, confirm the investor type and address, and click “Continue”. If the new submission data is correct, the old record(s) will remain on file, but will be marked as “Inactive”. Please be advised that if this latter option is chosen then a certificate of tax residence (e.g. an IRS Form 6166) will be required in order to change the record and prove that the information being entered is true and correct.

If you notice any issues with this update or have any questions, please don’t hesitate to contact Acupay’s A-Team.