Your withholding tax reclaim system is bought. Now it has to keep deadlines.

• Licensed, but not in production

  The withholding tax reclaim system has been procured, the vendor training was months ago. Applications are still produced the old way. Nobody in the business unit has the time to think the process through to the end inside the system, and nobody has been named to do it.

• Deadlines live in Excel

  Filing deadlines differ by source country and often run for years after the dividend is received. Who has to file what, where and by when is kept by one person in a list – because the system does not show the deadline per case the way the team needs it to decide.

• Documents are missing, and nobody sees it

  Certificate of residence, power of attorney, tax voucher or dividend statement: an application is only complete when every document required by the source country is in place. Without a completeness indicator in the system, the gap shows up at dispatch – or when the authority queries the claim.

• The custody chain is not in the system

  When a fund management company takes over the reclaim that used to sit with the depositary, the data set the system assumes is often missing: sub-custodians, central securities depositories, reallocations during the year. The system asks for data nobody in-house ever had to record.

• The interface to fund accounting blocks

  Holdings, income and tax withheld come from the back-office or fund accounting system. If granularity, reference date or identifier do not match, the import gets stuck. Business unit and development then discuss the same problem in two different languages.

• MiKaDiv has a date, the process does not

  From 1 January 2027, capital income from shares and depositary receipts must be reported electronically to the BZSt. The format is manageable. What is usually open is who delivers the custody chain per holding, who checks and who approves under the four-eyes principle before the report goes out.

• Withholding tax reclaim (standard refund)
• Relief procedure under § 50c EStG
• Relief at source (Vorabbefreiung)
• Quick refund
• Double taxation treaty (DTT)
• Certificate of residence
• Tax voucher and dividend statement
• Power of attorney
• Filing deadlines and statute of limitations
• Custody chain and sub-custodians
• Four-eyes principle
• MiKaDiv (§§ 45b, 45c EStG)
• FASTER Directive and eTRC
• OECD TRACE

Reclaim procedure (standard refund)

Withholding tax is first deducted in full; the beneficial owner or its authorised agent subsequently claims the difference to the treaty rate from the source country's authority. The slowest but most common route – and the one in which most deadlines and documents have to be managed.

Relief procedure and relief at source (Vorabbefreiung)

The reduced rate is applied at the time of distribution. In Germany, § 50c EStG governs the relief procedure; an exemption certificate is valid for at most three years, and applications have been filed electronically with the BZSt since 2024. Saves liquidity, but requires complete documentation before payment date.

Double taxation treaty (DTT)

Bilateral agreement limiting the withholding tax rate a state may deduct from residents of the other state. The reclaim entitlement arises from the difference between the rate withheld and the treaty rate.

Certificate of residence

Confirmation from the local tax office that the applicant is tax resident in the treaty state. A mandatory document in many procedures; from 2030 the FASTER Directive replaces it with a digital certificate (eTRC).

Tax voucher (Steuerbescheinigung)

Evidence of the capital gains tax withheld, issued in Germany by the paying agent. With MiKaDiv, its contents are additionally reported electronically to the BZSt (§ 45b EStG).

Power of attorney

Allows the custodian bank, the depositary or the fund management company to file applications in the name of the beneficial owner. If it is missing or expired, the application is formally incomplete – however correct the figures are.

Filing deadlines and statute of limitations

Every source country sets its own deadlines, counted from receipt of the income. For the German reclaim procedure under § 50c EStG the deadline is four years from the end of the year of receipt. A deadline that is not visible per case in the system ends up in an Excel list.

Custody chain and sub-custodians

All stations through which a security is held from the central securities depository down to the investor's account. Authorities and MiKaDiv want to trace it; the system needs it per holding and reference date.

Four-eyes principle

No filing and no report without a second approval. In the system this means: a dedicated status, a named owner and a trail of who checked what and when.

MiKaDiv

Reporting procedure for capital gains tax on dividends from shares and depositary receipts (§§ 45b, 45c EStG). Applies to capital income received after 31 December 2026; reports to the BZSt with fixed dates in the following year (31 March, 30 April, 31 July).

1. 01

   Shared language before the first screen

   Domain knowledge is scattered: among developers, the product owner, tax specialists, management. Before we design an interface, we build a glossary and a regulatory mapping – which term means which obligation, which deadline, which document. Only when everyone understands the same thing by 'open' or 'approved' is design worth doing. Otherwise people discuss screens and mean processes.

2. 02

   Status is the actual product

   In the business unit the question is never 'where is the button' but 'what is going on with this case, and do I have to do something today'. A status model that makes deadline, document completeness and approval visible per case replaces more Excel lists than any new feature. Where it is missing, the team builds its own – in a spreadsheet.

3. 03

   Expert users do not want simplification, they want control

   Users in tax and operations work with regulated workflows, audit trails and documents. Hiding complexity does not help them; it has to become manageable, auditable and safe. Filters, bulk actions and traceable validation matter more here than a tidy dashboard.

4. 04

   The Excel list is a finding, not misconduct

   Every parallel list answers a question the system does not answer. Banning it loses the information; reading it reveals the missing status, the missing document or the stuck interface. That is why every as-is analysis of ours starts with the lists, not with the manual.

5. 05

   A prototype with real data decides more than a concept paper

   Stakeholders judge product direction by something that feels like software. A clickable prototype with realistic cases, deadlines and errors brings business unit, development and sales to a decision faster than any specification – and shows early where the status model does not hold.

Frequently asked questions

Do you work for the vendor or for us?

Always for one side only per project. If your fund management company, depositary or bank engages us for the rollout, we work for you and represent your requirements towards the vendor. If a vendor engages us for UX, we work for the vendor. Information from one engagement does not flow into another.

Do you need access to our data or systems?

For the as-is analysis, observation in the business unit, anonymised examples and the existing Excel lists are enough. We do not need access to production data. For UAT and key-user work we use test or training environments. An NDA and, where required, a DORA addendum are standard for us.

Which role do you fill in the project?

Depending on the phase: UX Consultant or UX Researcher, Business Analyst with a focus on tax reporting, Requirements Engineer for functional and test concepts, or rollout support from UAT to hypercare. In tenders we best match 'Business Analyst / UX Consultant Tax Reporting' or 'Requirements Engineer Banking Applications'.

How quickly will we see results?

The as-is analysis delivers a process map and the list of gaps between process and system after two to four weeks. Measurable improvements – applications filed on time, parallel lists closed – come once priorities are set and we accompany daily operations. We estimate the timeframe together in the initial conversation.

What does MiKaDiv change for us from 2027?

For capital income from shares and depositary receipts received after 31 December 2026, paying agents and central securities depositories report data electronically to the BZSt (§§ 45b, 45c EStG), with fixed dates in the following year. The format is the smaller problem. What matters is whether the custody chain per holding is in the system and who approves the report before it is sent.

Does the FASTER Directive already affect us?

Not operationally yet: Directive (EU) 2025/50 has to be transposed by 31 December 2028 and applies from 1 January 2030. It brings a digital tax residence certificate (eTRC), relief at source and quick refund within 60 days, and a register of certified financial intermediaries. Whoever introduces a clean status model and document logic today will not have to start over in 2030.

Do you take on training and the key-user concept?

Yes. We create the key-user concept, training material based on the real process, and accompany the first weeks after go-live. The goal is that key users guide their colleagues themselves and we can step back.

Do you work remotely?

Yes, mostly. Our base is Munich; on-site days in Frankfurt and across the DACH region are possible by arrangement, for example for observation in the business unit, workshops or UAT days. We do not name reference clients; the only public case is the UX consulting for the vendor.