Recital (9)

The eTRC should contain a reference to the double tax treaty in relation to which a taxpayer requests to be considered resident for tax purposes, where applicable. In order for the eTRC to be recognised by the source Member State as a valid proof of tax residence, where relief of excess withholding tax is claimed under the provisions of a double tax treaty, it is essential that the eTRC include a reference to the applicable double tax treaty. It should be possible for the issuing authority to refer to more than one applicable double tax treaty on a given eTRC. While primarily intended for the implementation of the withholding tax procedures, the eTRC could also have a wider scope of application and serve for proving the residence for tax purposes beyond withholding tax procedures. For the purposes of relief of withholding tax procedures, the eTRC should not include any additional information. The eTRC is intended to be issued only once during the calendar year or once during the fiscal year, even when the same taxpayer invests on multiple occasions in the same source Member States, as long as the taxpayer’s residence for tax purposes remains the same.