Qualified Intermediary

Practical Compliance in Cross-Border Income Taxation and Anti-Tax Evasion

By: Ross K. McGill, Kirsty V. Pitkin

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eText | 15 March 2025

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Multiple jurisdictions have been and continue to converge their taxation frameworks to eradicate cross-border tax evasion and establish common principles under which non- resident financial institutions can become withholding agents for non-resident investors and establish rules to prevent and detect cross-border tax evasion.

The US began this convergence with its Qualified Intermediary agreement framework in 2001 with Revenue Procedure 2000-12 (the "QI Agreement"). Ireland followed the US model with its Qualified Intermediary and Authorised Withholding Agent ("AWA") program and Japan has adopted a Qualified Foreign Intermediary ("QFI") system. More recently, in 2023 the European Commission proposed a new Directive for standardisation and simplification of cross-border withholding tax across 27 Member States ("FASTER"). Once agreed upon, the Directive is expected to go into force on January 1, 2030.

All these frameworks have a commonality of purpose and, in many cases, commonality of implementation principles. Differences lie in the practical implementation of these frameworks by financial institutions who may have to adopt different procedures and policies depending on the nature and residency of their clients and the markets in which they choose to invest. This book will be of interest to financial services professionals and institutional investors, including custodians and brokers.