Implement BZSt reporting requirements

MiKaDiv as amendment to the AbZstEntModG

In June 2021, the Act to modernize the relief from withholdingtTaxes and certification of capital gains taxes (AbzStEntModG) came into force. The electronic notification requirement and stricter liability rules for incorrect information are intended to create greater transparency.  The new reporting procedure MiKaDiv is now being introduced by the BZSt to prevent abuse in the taxation of dividends and to enable the refund of withheld capital gains tax. 

Who is affected by the new procedure?

With the new reporting procedure, custodian banks and other domestic paying agents must report to the Bundeszentralamt für Steuern (BZSt) which capital income has been paid to investors in Germany and abroad. Domestic listed companies must also inform the BZSt about their shareholders. The BZSt collects this data and uses it as part of refund and credit procedures. 

Supplementary data

  • Report General Data 
  • Customer data (e.g. account/custody account number, information on trustee) 
  • Chain of custody (e.g. LEI, legal status) 
  • Securities information (e.g. capital income, number of securities) 
  • Depository receipts (e.g. ISIN of deposited securities, subscription ratio) 

Reporting requirements

  • Resident taxpayers: digital reporting of additional data and on the tax certificate 
  • Non-resident taxpayers: digital reporting instead of tax certificate 
  • Notification of not issued tax certificate or not carried out notifications 
  • Exemption report (report of not or not completely collected tax deduction) 

Aktuelle Entwicklungen

Als erstes und bislang einziges OECD-Land hat Finnland die TRACE-Richtlinien in sein geltendes Recht integriert. Dabei schafft Finnland jedoch keine verbindliche Teilnahme für Finanzintermediäre und Anleger, sondern behält zwei bestehende Verfahren bei: das nachgelagerte Erstattungsverfahren (Standard Refund) sowie die finnische Tax at Source Card.

Implementation of MiKaDiv requirements

BZSt is gradually preparing for fully digitized reporting. It announced a mass data interface for the procedure and already provided beta versions of the submission data sets at the beginning of the year. (Individual procedures such as electronic application submission and notice retrieval are already required by law as of January 1, 2023). Banks and implementation partners now have about 2 years until the interface goes live, as digital reporting for tax withholding on dividend payments will be mandatory from 2025. The go-live of the test platform is already planned for June 2024.  It is now time to clarify functional and technical issues, check necessary processes, and prepare for data collection/transmission.

We are implementation partners for our clients

We have been dealing with the new procedure for a while and set up an Expert Group on AbzStEntModG/MiKaDiv to maintain a constant exchange with our clients’ experts. 

We have established a separate Expert Group for the new digital interface at the BZSt and the associated tax reclaim process. In addition, our participation in the MiKaDiv User Group and the User Group Mass Data Interface for Capital Gains Tax Refund at the BZSt in Berlin gives us direct access to the implementing authority. 

Based on discussions with various financial institutions, the development of software components in RAQUEST is already in progress. 

With our STTI interface, we have created the base for digital data transmission to various tax authorities (such as for the markets in Denmark, Switzerland, and even Austria). This will now be expanded to include the gateway to the BZSt. 

Functionally, we will address the digital application for tax reclaims at the BZSt, new data deliveries, and new depository functions. 

Data delivery for foreign financial institution

  • Extension of import interfaces 
  • Support for integration and reporting of purchases and sales 
  • Easy provision of tax reports and tax certificates 
  • Transfer of relevant data (master data, tax data, revenue data and settlement, purchases, and sales, payment chain information) 
  • Import of tax reports 
  • Integration of the reporting process into the digital claiming process 

Processing for domestic custodians

  • Import of requests for tax returns and tax certificates 
  • Import of additional client data (master data, tax data, revenue data, settlement, purchases, and sales, payment chain information) 
  • Checking consistency of supplied data 
  • Generation of information for MiKaDiv notifications 
  • Creation and management of extended tax certificate from 2025 for tax residents 
  • Creation of ordinal number (UUID) 

MiKaDiv Countdown

Coming soon:
Go-Live BZSt testing platform

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Manfred Artmeier RAQUEST

Manfred Artmeier

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