All banks that would like to send recovery requests to the German Federal Central Tax Office (BZSt) in the future will need a solution for digital submission. The new mass data interface is already in development by the German Federal Central Tax Office with a planned deployment in 2024. In order to engage future users at an early stage, the German Federal Central Tax Office has set up a user group in which we are participating. Taking part in the exchange of experts gives us direct access to the implementing authority.
With our STTI interface, we have already created the basis for digital data transmission to various tax authorities (such as for the markets in Denmark, Switzerland or even Austria). In the meantime, the requirements for the interface have been communicated by the BZSt, enabling us to start with the extension of STTI by adding the module to the BZSt. However, according to the draft KAFe procedure, the interface is extremely data hungry. Much of the required information is currently not yet available in RAQUEST. Hence, interface extensions are necessary to ensure effective implementation.
The timely implementation of this process will be particularly challenging, as it has no longer been possible since the middle of this year to reclaim income from 2020 via the submission of paper claims. In order to avoid problems with the limitation period for 2020 claims, it is essential for banks to start the implementation process in a prompt manner.
Furthermore, the current draft of the proposal contains some requirements which could potentially lead to a disadvantage for investors entering the German investment market. As a consequence, we intend to provide critical feedback to the German Federal Central Tax Office (BZSt) in order to strive for improvements and to achieve a balanced solution. We have yet to see what steps the BZSt will take to optimize the interface and meet the needs of investors.