Annexes to COM(2023)324 - Faster and Safer Relief of Excess Withholding Taxes - Main contents
Please note
This page contains a limited version of this dossier in the EU Monitor.
| dossier | COM(2023)324 - Faster and Safer Relief of Excess Withholding Taxes. |
|---|---|
| document | COM(2023)324 |
| date | June 19, 2023 |
1.5. Grounds for the proposal/initiative
1.5.1. Requirement(s) to be met in the short- or long-term including a detailed timeline for roll-out of the implementation of the initiative
1.5.2. Added value of Union involvement (it may result from different factors, e.g. coordination gains, legal certainty, greater effectiveness or complementarities). For the purposes of this point 'added value of Union involvement' is the value resulting from Union intervention which is additional to the value that would have been otherwise created by Member States alone
1.5.3. Lessons learned from similar experiences in the past
1.5.4. Compatibility with the Multiannual Financial Framework and possible synergies with other appropriate instruments
1.5.5. Assessment of the different available financing options, including scope for redeployment
1.6. Duration and financial impact of the proposal/initiative
limited duration
in effect from [DD/MM]YYYY to [DD/MM]YYYY
Financial impact from YYYY to YYYY for commitment appropriations and from YYYY to YYYY for payment appropriations.
- X unlimited duration
Implementation with a start-up period from YYYY to YYYY,
followed by full-scale operation.
1.7. Management mode(s) planned
- X Direct management by the Commission
X by its departments, including by its staff in the Union delegations;
by the executive agencies
- Shared management with the Member States
- Indirect management by entrusting budget implementation tasks to:
third countries or the bodies they have designated;
international organisations and their agencies (to be specified);
the EIB and the European Investment Fund;
bodies referred to in Articles 70 and 71 of the Financial Regulation;
public law bodies;
bodies governed by private law with a public service mission to the extent that they are provided with adequate financial guarantees;
bodies governed by the private law of a Member State that are entrusted with the implementation of a public-private partnership and that are provided with adequate financial guarantees;
persons entrusted with the implementation of specific actions in the CFSP pursuant to Title V of the TEU, and identified in the relevant basic act.
2. MANAGEMENT MEASURES
2.1. Monitoring and reporting rules
2.2. Management and control system(s)
2.2.1. Justification of the management mode(s), the funding implementation mechanism(s), the payment modalities and the control strategy proposed
2.2.2. Information concerning the risks identified and the internal control system(s) set up to mitigate them
With regard to ensuring that WHT reclaims are refunded/relieved within the time limits, Member States will be required to report to the Commission on an annual basis statistics on how many excess WHT reclaims were refunded/relieved within the time limits and how many beyond the time limits. For the latter, a justification should be provided. Further, Member States will be required to make late interest payments to the taxpayer for refunds beyond the time limits without justification.
With regard to compliance of their certified financial intermediaries in the national registers, Member States will provide an annual report to the Commission on the audits and activities they have undertaken to ensure the compliance of their financial intermediaries with their obligations of the Directive, including reporting obligations. Further, financial intermediaries shall be held liable for the breach of their obligations under this Directive if their conduct has resulted in a loss of tax revenue.
Member States will be required to provide an annual report to the Commission on the use of data reported under the Directive to detect and combat excess WHT relief/refund abuse.
The main elements of the control strategy are:
Procurement contracts
The control procedures for procurement defined in the Financial Regulation: any procurement contract is established following the established procedure of verification by the services of the Commission for payment, taking into account contractual obligations and sound financial and general management. Anti-fraud measures (controls, reports, etc.) are foreseen in all contracts concluded between the Commission and the beneficiaries. Detailed terms of reference are drafted and form the basis of each specific contract. The acceptance process follows strictly the TAXUD TEMPO methodology: deliverables are reviewed, amended if necessary and finally explicitly accepted (or rejected). No invoice can be paid without an "acceptance letter".
Technical verification of procurement
DG TAXUD performs controls of deliverables and supervises operations and services carried out by contractors. It also conducts quality and security audits of their contractors on a regular basis. Quality audits verify the compliance of the contractors' actual processes against the rules and procedures defined in their quality plans. Security audits focus on the specific processes, procedures and set-up.
In addition to the above controls, DG TAXUD performs the traditional financial controls:
Ex-ante verification of commitments
All commitments in DG TAXUD are verified by the Head of the Finances and the HR business correspondent Unit. Consequently, 100% of the committed amounts are covered by the ex-ante verification. This procedure gives a high level of assurance as to the legality and regularity of transactions.
Ex-ante verification of payments
100% of payments are verified ex-ante. Moreover, at least one payment (from all categories of expenditures) per week is randomly selected for additional ex-ante verification performed by the head of the Finances and HR business correspondent Unit. There is no target concerning the coverage, as the purpose of this verification is to check payments "randomly" in order to verify that all payments were prepared in line with the requirements. The remaining payments are processed according to the rules in force on a daily basis.
Declarations of the Authorising Officers by Sub-Delegations (AOSD)
All the AOSD sign declarations supporting the Annual Activity Report for the year concerned. These declarations cover the operations under the programme. The AOSD declare that the operations connected with the implementation of the budget have been executed in accordance with the principles of the sound financial management, that the management and control systems in place provided satisfactory assurance concerning the legality and regularity of the transactions and that the risks associated to these operations have been properly identified, reported and that mitigating actions have been implemented.
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio of "control costs ÷ value of the related funds managed"), and assessment of the expected levels of risk of error (at payment & at closure)
2.3. Measures to prevent fraud and irregularities
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL
3.1 Heading(s) of the multiannual financial framework and expenditure budget line(s) affected
Existing budget lines
In order of multiannual financial framework headings and budget lines.
| Heading of multiannual financial framework | Budget line | Type of expenditure | Contribution | |||
| Number: 03 04 0100 | Diff./Non-diff.46 | from EFTA countries47 | from candidate countries48 | from third countries | within the meaning of Article 21(2)(b) of the Financial Regulation | |
| 1 - Single Market, Innovation and Digital | Improving the proper functioning of the taxation systems | Diff. | NO | NO | NO | NO |
New budget lines requested
In order of multiannual financial framework headings and budget lines.
| Heading of multiannual financial framework | Budget line | Type of expenditure | Contribution | |||
| Number | Diff./Non-diff. | from EFTA countries | from candidate countries | from third countries | within the meaning of Article 21(2)(b) of the Financial Regulation | |
| [XX.YY.YY.YY] | YES/NO | YES/NO | YES/NO | YES/NO |
3.2 Estimated financial impact of the proposal on appropriations
3.2.1 Summary of estimated impact on operational appropriations
The proposal/initiative does not require the use of operational appropriations
The proposal/initiative requires the use of operational appropriations, as explained below:
EUR million (to three decimal places)
| Heading of multiannual financial framework | Number 1 | Single Market, Innovation and Digital |
| DG: TAXUD | 2023 | 2024 | 2025 | 2026 | Enter as many years as necessary to show the duration of the impact (see point 1.6) | TOTAL | |||||
| Operational appropriations | |||||||||||
| Budget line49 03.04.01 | Commitments | (1a) | 0.150 | 0.400 | 0.200 | 0.330 | 0.180 | 1.26 | |||
| Payments | (2a) | 0.150 | 0.400 | 0.200 | 0.330 | 0.180 | 1.26 | ||||
| Budget line | Commitments | (1b) | |||||||||
| Payments | (2b) | ||||||||||
| Appropriations of an administrative nature financed from the envelope of specific programmes50 | |||||||||||
| Budget line | (3) | ||||||||||
| TOTAL appropriations for DG TAXUD | Commitments | =1a+1b +3 | 0.150 | 0.400 | 0.200 | 0.330 | 0.180 | 1.26 | |||
| Payments | =2a+2b+3 | 0.150 | 0.400 | 0.200 | 0.330 | 0.180 | 1.26 |
| Heading of multiannual financial framework | 7 | ‘Administrative expenditure’ |
This section should be filled in using the 'budget data of an administrative nature' to be firstly introduced in the Annex to the Legislative Financial Statement (Annex V to the internal rules), which is uploaded to DECIDE for interservice consultation purposes.
EUR million (to three decimal places)
TOTAL appropriations
under HEADING 7
of the multiannual financial framework
(Total commitments = Total payments)
0.122
0.161
0.159
0.065
0.017
0,524
EUR million (to three decimal places)
2023
2024
2025
2026
2027
TOTAL
2021 – 2027 MFF
TOTAL appropriations
under HEADINGS 1 to 7
of the multiannual financial framework
Commitments
0.272
0.561
0.359
0.395
0.197
1,784
Payments
0.122
0.311
0.559
0.265
0.347
1,604
TOTAL appropriations
under HEADINGS 1 to 7
of the multiannual financial framework
3.2.2. Estimated impact on operational appropriations
The proposal/initiative does not require the use of operational appropriations
The proposal/initiative requires the use of operational appropriations, as explained below:
Commitment appropriations in EUR million (to three decimal places)
| Indicate objectives and outputs | 2023 | 2024 | 2025 | 2026 | 2027 | 2028 | TOTAL | |||||||||
| OUTPUTS | ||||||||||||||||
| Type51 | Average cost | No | Cost | No | Cost | No | Cost | No | Cost | No | Cost | No | Cost | Total No | Total cost | |
| SPECIFIC OBJECTIVE No 152… | ||||||||||||||||
| Specifications | 0.150 | 0.100 | 0.250 | |||||||||||||
| Development | 0.300 | 0.200 | 0.150 | 0.650 | ||||||||||||
| Maintenance | 0.100 | 0.100 | 0.100 | 0.300 | ||||||||||||
| Support | 0.020 | 0.020 | 0.020 | 0.020 | 0.080 | |||||||||||
| Training | 0.020 | 0.020 | ||||||||||||||
| ITSM (Infrastructure, hosting, licences, etc.), | 0.020 | 0.060 | 0.060 | 0.060 | 0.060 | 0.260 | ||||||||||
| Subtotal for specific objective No 1 | 0.150 | 0.420 | 0.300 | 0.330 | 0.180 | 0.180 | 1.560 | |||||||||
| SPECIFIC OBJECTIVE No 2 ... | ||||||||||||||||
| - Output | ||||||||||||||||
| Subtotal for specific objective No 2 | ||||||||||||||||
| TOTALS | 0.150 | 0.420 | 0.300 | 0.330 | 0.180 | 0.180 | 1.560 |
3.2.3 Summary of estimated impact on administrative appropriations
The proposal/initiative does not require the use of appropriations of an administrative nature
The proposal/initiative requires the use of appropriations of an administrative nature, as explained below:
EUR million (to three decimal places)
| Year 2023 | Year 2024 | Year 2025 | Year 2026 | Year 2027 | TOTAL |
| HEADING 7 of the multiannual financial framework | ||||||
| Human resources | 0.118 | 0.157 | 0.157 | 0.063 | 0.016 | 0,511 |
| Other administrative expenditure | 0.004 | 0.004 | 0.002 | 0.002 | 0.001 | 0,013 |
| Subtotal HEADING 7 of the multiannual financial framework | ||||||
| TOTAL | 0.122 | 0.161 | 0.159 | 0.065 | 0.017 | 0,524 |
| Outside HEADING 753 of the multiannual financial framework | ||||||
| Human resources | ||||||
| Other expenditure of an administrative nature | ||||||
| Subtotal outside HEADING 7 of the multiannual financial framework |
| TOTAL | 0.122 | 0.161 | 0.159 | 0.065 | 0.017 | 0,524 |
The appropriations required for human resources and other expenditure of an administrative nature will be met by appropriations from the DG that are already assigned to management of the action and/or have been redeployed within the DG, together if necessary with any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary constraints.
3.2.3.1 Estimated requirements of human resources
The proposal/initiative does not require the use of human resources.
The proposal/initiative requires the use of human resources, as explained below:
| 2023 | 2024 | 2025 | 2026 | 2027 | Total | |||
| Establishment plan posts (officials and temporary staff) | ||||||||
| 20 01 02 01 (Headquarters and Commission’s Representation Offices) | 0.75 | 1 | 1 | 0.4 | 0.1 | 3.25 | ||
| 20 01 02 03 (Delegations) | ||||||||
| 01 01 01 01 (Indirect research) | ||||||||
| 01 01 01 11 (Direct research) | ||||||||
| Other budget lines (specify) | ||||||||
| External staff (in Full Time Equivalent unit: FTE)54 | ||||||||
| 20 02 01 (AC, END, INT from the ‘global envelope’) | ||||||||
| 20 02 03 (AC, AL, END, INT and JPD in the delegations) | ||||||||
| XX 01 xx yy zz 55 | - at Headquarters | |||||||
| - in Delegations | ||||||||
| 01 01 01 02 (AC, END, INT - Indirect research) | ||||||||
| 01 01 01 12 (AC, END, INT - Direct research) | ||||||||
| Other budget lines (specify) | ||||||||
| TOTAL | 0.75 | 1 | 1 | 0.4 | 0.1 | 3.25 |
Estimate to be expressed in full time equivalent units
XX is the policy area or budget title concerned.
The human resources required will be met by staff from the DG who are already assigned to management of the action and/or have been redeployed within the DG, together if necessary with any additional allocation which may be granted to the managing DG under the annual allocation procedure and in the light of budgetary constraints.
Description of tasks to be carried out:
| Officials and temporary staff | Preparation of meetings and correspondence with Member States; work on forms, IT formats and the Central Directory; Commission of external contractors to do work on the IT system. |
| External staff | N/A |
3.2.4 Compatibility with the current multiannual financial framework
The proposal/initiative:
can be fully financed through redeployment within the relevant heading of the Multiannual Financial Framework (MFF).
Explain what reprogramming is required, specifying the budget lines concerned and the corresponding amounts. Please provide an excel table in the case of major reprogramming.
requires use of the unallocated margin under the relevant heading of the MFF and/or use of the special instruments as defined in the MFF Regulation.
Explain what is required, specifying the headings and budget lines concerned, the corresponding amounts, and the instruments proposed to be used.
requires a revision of the MFF.
Explain what is required, specifying the headings and budget lines concerned and the corresponding amounts.
3.2.5 Third-party contributions
The proposal/initiative:
does not provide for co-financing by third parties
provides for the co-financing by third parties estimated below:
Appropriations in EUR million (to three decimal places)
| Year N56 | Year N+1 | Year N+2 | Year N+3 | Enter as many years as necessary to show the duration of the impact (see point 1.6) | Total | |||
| Specify the co-financing body | ||||||||
| TOTAL appropriations co-financed |
3.3 Estimated impact on revenue
The proposal/initiative has no financial impact on revenue.
The proposal/initiative has the following financial impact:
on own resources
on other revenue
please indicate, if the revenue is assigned to expenditure lines ◻
EUR million (to three decimal places)
| Budget revenue line: | Appropriations available for the current financial year | Impact of the proposal/initiative57 | ||||||
| Year N | Year N+1 | Year N+2 | Year N+3 | Enter as many years as necessary to show the duration of the impact (see point 1.6) | ||||
| Article …………. |
For assigned revenue, specify the budget expenditure line(s) affected.
Other remarks (e.g. method/formula used for calculating the impact on revenue or any other information).
1Withholding tax on dividends, survey for investors in the European Union, Better Finance, March 2023.
2https://finance.ec.europa.eu/publications/retail-investment-package_en
3Commission Recommendation of 19 October 2009 on withholding tax relief procedures (OJ L 279, 24.10.2009, p. 8–11).
4European Commission (2017), Code of conduct on withholding tax, Directorate-General Taxation and Customs Union, https://taxation-customs.ec.europa.eu/system/files/2017-12/code_of_conduct_on_witholding_tax.pdf) .
5OECD (2013), TRACE implementation package for the adoption of the authorised intermediary system: A standardised system for effective withholding tax relief procedures for cross-border portfolio income (https://www.oecd.org/ctp/exchange-of-tax-information/treatyreliefandcomplianceenhancementtrace.htm).
6See impact assessment report accompanying this proposal.
7Communication From The Commission To The European Parliament And The Council An Action Plan For Fair And Simple Taxation Supporting The Recovery Strategy (COM/2020/312 final)
8Communication From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions A Capital Markets Union For People And Businesses-New Action Plan (COM/2020/590 final)
9European Parliament resolution of 10 March 2022 with recommendations to the Commission on fair and simple taxation supporting the recovery strategy (EP follow-up to the July Commission’s Action Plan and its 25 initiatives in the area of VAT, business and individual taxation) (2020/2254(INL)) (OJ C 347, 9.9.2022, p. 211–222)
10European Parliament resolution of 10 March 2022 on a European Withholding Tax framework (2021/2097(INI))
11European Parliament resolution of 8 October 2020 on further development of the Capital Markets Union (CMU): improving access to capital market finance, in particular by SMEs, and further enabling retail investor participation (2020/2036(INI))
12See impact assessment report accompanying this proposal.
13Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (OJ L 193, 19.7.2016, p. 1)
14Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC (OJ L 64, 11.3.2011, p. 1)
15Council Directive 2014/107/EU of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (OJ L 359, 16.12.2014, p. 1–29)
16Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (OJ L 139, 5.6.2018, p. 1–13)
17Proposal for a Council Directive of 22 December 2021 laying down rules to prevent the misuse of shell entities for tax purposes and amending Directive 2011/16/EU (COM(2021)565).
18Council Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (recast) (OJ L 345, 29.12.2011, p. 8–16)
19Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States (OJ L 157, 26.6.2003, p. 49–54)
20Proposal for a Directive of the European Parliament and of the Council amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the Union retail investor protection rules (COM/2023/279 final)
21Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement.
22Inception Impact Assessment - Ares(2021)5900310 (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13031-Withholding-taxes-new-EU-system-to-avoid-double-taxation_en)
23Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, p. 73–114)
24Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 (OJ L 176, 27.6.2013, p. 1–337)
25Regulation (EU) No 909/2014 of the European Parliament and of the Council of 23 July 2014 on improving securities settlement in the European Union and on central securities depositories and amending Directives 98/26/EC and 2014/65/EU and Regulation (EU) No 236/2012 (OJ L 257, 28.8.2014, p. 1–72)
26OJ C , , p. .
27OJ C , , p. .
28Commission Recommendation of 19 October 2009 on withholding tax relief procedures (Text with EEA relevance) (OJ L 279, 24.10.2009, p. 8–11)
29Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 Text with EEA relevance (OJ L 176, 27.6.2013, p. 1–337)
30Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission’s exercise of implementing powers (OJ L 55, 28.2.2011, p. 13)
31Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1)
32Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39)
33 Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU (recast) (OJ L 173, 2.6.2014, p. 349)
34Regulation (EU) No 909/2014 of the European Parliament and of the Council of 23 July 2014 on improving securities settlement in the European Union and on central securities depositories and amending Directives 98/26/EC and 2014/65/EU and Regulation (EU) No 236/2012 (OJ L 257, 28.8.2014, p. 1–72)
35Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 Text with EEA relevance (OJ L 176, 27.6.2013, p. 1–337)
36Directive (EU) 2017/1132 of the European Parliament and of the Council of 14 June 2017 relating to certain aspects of company law (codification) (OJ L 169, 30.6.2017, p. 46–127)
37 Commission Implementing Regulation (EU) 2018/1212 of 3 September 2018 laying down minimum requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and the Council as regards shareholder identification, the transmission of information and the facilitation of the exercise of shareholder rights (OJ L 223, 4.9.2018, p. 1).
38Guideline (EU) 2019/1265 of the European Central Bank of 10 July 2019 on the euro short-term rate (€STR) (ECB/2019/19) (OJ L 199, 26.7.2019, p. 8–17)
39Council of the European Union, Economic and Financial Affairs Council, 14094/16, Brussels 8 November 2016
40Commission Delegated Regulation (EU) 2016/1675 of 14 July 2016 supplementing Directive (EU) 2015/849 of the European Parliament and of the Council by identifying high-risk third countries with strategic deficiencies (OJ L 254, 20.9.2016, p. 1–4)
41Council Directive 2014/107/EU of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (OJ L 359, 16.12.2014, p. 1–29)
42Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU (OJ L 156, 19.6.2018, p. 43–74)
43Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (OJ L 141, 5.6.2015, p. 73–117)
44Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission’s exercise of implementing powers (OJ L 55, 28.2.2011, p. 13–18)
45Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (OJ L 119, 4.5.2016, p. 1).
46Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations.
47EFTA: European Free Trade Association.
48Candidate countries and, where applicable, potential candidates from the Western Balkans.
49According to the official budget nomenclature.
50Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.
51Outputs are products and services to be supplied (e.g.: number of student exchanges financed, number of km of roads built, etc.).
52As described in point 1.4.2. ‘Specific objective(s)…’
53Technical and/or administrative assistance and expenditure in support of the implementation of EU programmes and/or actions (former ‘BA’ lines), indirect research, direct research.
54AC= Contract Staff; AL = Local Staff; END= Seconded National Expert; INT = agency staff; JPD= Junior Professionals in Delegations.
55Sub-ceiling for external staff covered by operational appropriations (former ‘BA’ lines).
56Year N is the year in which implementation of the proposal/initiative starts. Please replace "N" by the expected first year of implementation (for instance: 2021). The same for the following years.
57As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net amounts, i.e. gross amounts after deduction of 20 % for collection costs.
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