Sirs,

I am writing on behalf of TConsult to explore a collaboration with the Ministry of Finance to support Estonia's implementation of the FASTER Directive.

The Commission’s published TSI programme includes support for a group of nine Member States preparing for FASTER. We are exploring a complementary commercial programme for other interested administrations, either individually or through collaboration between countries with similar requirements.

TConsult specialises in international withholding tax and financial intermediary compliance. I have worked in this field since 1996, participate in the Commission’s FASTER Large Working Group and I am the chairman the Association of Qualified & Authorised Intermediaries.

Our proposed approach would connect the Directive’s requirements with the practical work needed within your administration and across the financial institutions serving your market. Depending on your priorities, this could include:

• Reviewing existing legislation, procedures, and systems to identify gaps and develop a phased implementation roadmap.

• Designing processes for electronic tax residence certificates, Certified Financial Intermediary registration and oversight, and investor declarations.

• Developing relief at source and quick refund procedures, including reporting, validation, reconciliation, and audit controls.

• Preparing functional and technical specifications, supported by a proof of concept to test selected processes before wider implementation.

• Addressing participation by non-EU intermediaries and the treatment of third-country investors and residence evidence.

• Preparing operational manuals, staff training, and structured consultation with financial intermediaries.

TConsult would lead the functional work, bringing together specialist technology and national legal expertise appropriate to the agreed scope. The work would follow the Directive and relevant Commission specifications and guidance as they develop, while accommodating national systems and permitted policy choices.

Where several administrations share requirements, a collaborative project could reduce duplicated design and testing costs, with separate national implementation plans and clear ownership of decisions.

Following an introductory discussion, we would propose an initial scoping assignment with an agreed fee and defined outputs. This would establish the priorities, responsibilities, timetable, and budget for any subsequent implementation programme.

Would you be available for a short discussion to explore whether this could support your current preparations? If responsibility sits elsewhere, I would appreciate an introduction to the colleague leading FASTER implementation.

Ross McGill Chairman Emeritus  [email protected]  01252 413551 | 07515356050  www.tconsult-ltd.com