SPL d.d.'s main activity is the management of multi-apartment buildings. Our initiative may seem at first sight to be more about systemic regulation of our business area, but in fact the main purpose is to simplify operations and reduce administration. We are writing to you in relation to the problem of excessive administration in the collection and tax accounting of rents for the letting of common areas in multi-apartment buildings where the manager is authorised under housing legislation to collect these rents. The collection of common area rents has a differential impact on the different stakeholders among the ground floor owners, as inequalities are created by the mere fact that individual ground floor owners who are natural persons and liable to tax under the Income Tax Act do not submit their tax numbers to the administrator. In addition to these, the floor owners are also legal persons and legal persons of a public nature, which are subject to bookkeeping obligations and are taxed under different tax legislation than natural persons. The non-receipt of data (tax numbers) by the ground floor owners and the different tax treatment of the different taxable persons also result in further inequalities between the different tenants of the common areas who receive the amount of their liability depending on the diversity of the ground floor owners and the possession of their data by the managers. The fact is that the manager manages to obtain between 85% and 90% of the tax numbers of natural persons, while most legal persons have no interest in issuing invoices and sending them monthly to the manager for such small amounts as come from the co-ownership of a rented common area in a building and for an activity for which, in most cases, they are not even registered. To give an idea of the actual situation, we can state that in 2014 we managed the rent of the common areas in 257 buildings, which means that 5864 owners were involved in the letting of the common areas, of which 5339 were natural persons who forwarded the TA to us and 385 who did not do so for various reasons, 92 were legal persons who sent us invoices and 140 who were not interested or sent invoices directly to the tenant in their own part. If we had charged the full rent, we would have charged €295,360 in 2014 but due to missing data and documents we only charged €242,945 which is 82.25% realisation. You are surely familiar with our market share (8%), so it is not difficult to calculate what these figures are for the whole of Slovenia. All this monthly administration for thousands (SPL) and tens of thousands (SLO) of owners could be unnecessary if the collection were taxed at the level of the income and not at the level of the recipient of the income as is currently the case. It would also reduce the burden on the computing capacity of both the administrators and the tax administration. At the same time, it should be borne in mind that owners change on a daily basis and, once again, new owners should be informed that they are to be included in the ultra-bureaucratic system of collecting common area rents and asked to provide information and documents. In order to eliminate these inequalities and excessive administration, we have already and are again proposing to simplify the tax accounting and to distribute the funds collected from the common area rentals in such a way that all these funds would be compulsorily paid into the building reserve fund (BRF) and subject to a special tax at the moment of payment into the BRF. Such direct payments to the RS and taxation could apply to all income received by all floor owners, such as: compensation for common parts, rooms and facilities, allowances, miscellaneous user charges and the like. We believe that this will not be incompatible with the European Directives, even though such a tax will be a special feature in the EU, as the RS institution is also such a special feature.