1. e-Data exchange between data subjects and data beneficiaries
Management companies (hereinafter "MCs")[1] face a large number of enquiries about possible investments in mutual funds or other securities. They receive enquiries from insolvency administrators, courts, the Commission for the Prevention of Corruption, the Ministry of Finance or the Financial Administration of the Republic of Slovenia, the Ministry of the Interior, prosecutors' offices, etc. These enquiries are time-consuming, both on the part of the DZU, which has to check the records and prepare and send a reply to the enquiry, and on the part of the authority sending the enquiry.
On the basis of the Act on the Enforcement of Public Entitlements[2], the e-Social data exchange system[3] was launched in 2012, which the Association considers to be very good and efficient, and we have repeatedly proposed to the relevant ministries that the legal basis be prepared to allow other users to switch to e-Social. We first made such a proposal back in 2014, and several meetings have been convened, but not much has changed since then. The legal basis for data exchange with the Financial Administration of the Republic of Slovenia and with housing funds has been adopted. We would like to point out that there is interest on the part of the Financial Administration of the Republic of Slovenia in the e-exchange of data in the case of foreclosures, while on the part of the housing fund, for which a test environment has already been prepared, we have been informed that they have new management that is not in favour of this project; there is also opposition to such an exchange of data on the part of the insolvency administrators and the courts, which say that they are not ready for such an exchange of data.
The UIAs have invested considerable financial resources in adapting their IT to the e-Social system and find it unacceptable that the e-Social system is used only for the exchange of data under the UIAA, while other queries still have to be answered by registered mail.  It should be borne in mind that each UBO, which employs on average only 41 people, responds to between 150 and 250 enquiries per month, which means between 37 and 65 working hours, plus the material costs of sending the replies. The DZU is not allowed to charge for the costs incurred.
The Association considers that, if a suitable legal basis were established, the same method of electronic enquiry and transmission of data could be used in other cases, provided that there was a willingness on the part of the persons requesting information from the DZU to do so.
On the basis of the above, we suggest that an obligation to provide for e-exchange should also be foreseen for enquiries:
bankruptcy trustees[4]public housing funds, municipalities or non-profit housing organisations providing housing units[5]social work centres[6]courts[7]prosecutorsFinancial Administration of the Republic of SloveniaCommission for Prevention of Corruption[8]Office of the Republic of Slovenia for the Prevention of MoneyMinistry of the Interiorother holders of public powers

Our proposal for more efficient e-commerce would reduce costs for all participants and speed up data retrieval procedures, while providing state authorities with fast and comprehensive information about the person they are dealing with.
On the basis of the above, we ask you to listen to our proposal and to extend the e-Data Exchange system to other segments or users.
We are confident that extending the e-reporting system to other segments, following the example of e-Social, would quickly pay off for these segments as well.

2. Proposal to amend or simplify the procedure for filing capital gains returns for investors who have made redemptions of mutual fund units in the past year.

Each year, the DZUs carefully prepare and submit to the Slovenian Tax Administration a 'DoH-CDVP' file containing all the data on the acquisitions and disposals of investment coupons by individual mutual fund investors[9]. The DZUs also provide investors who have made withdrawals of units from mutual funds in the previous year with all the information necessary for the calculation of the capital gains tax and invite them to submit their own capital gains tax return.

In order to simplify the procedures, reduce the administrative burden and improve the situation in the area of filing returns, we propose that the process be changed so that the Financial Administration of the Republic of Slovenia prepares and issues decisions to individual investors (at least to those investors who have not made any other disposals of securities in the previous year and/or have not covered losses from previous years) on the basis of the information provided by the DZU in the 'DoH-CDVP' file.

We believe that our proposals above are of benefit to all those involved in the exchange of information or the filing of tax returns. Procedures will be faster, cheaper, typing will no longer be wasted and there will be no "typos". The capital gains procedure would follow the decision-making procedure for income tax, which works perfectly well.

[1] All Slovenian CFCUs are our members
[2] Act on the enforcement of rights from public funds (Journal of Laws of the Republic of Slovenia No. 62/2010 with all amendments and supplements; hereinafter referred to as the "ZUPJS").
[3] E-Social is a system for the exchange of data between social work centres and databases maintained by the operators listed in Article 51(2) ( including management companies, brokerage houses, credit institutions, insurance companies, etc.).

[4] Article 384(8) of the ICAPL
[5] Article 11a(12) SZ-1
[6] (Article 34a of the ZUP and Article 246 of the Family Code).
[7] The most frequent inquiries are in succession matters.
[8] verification of the assets of the debtors
[9] Article 339 of the Income Tax Code-2