Qualified Intermediary

Qualified Intermediary

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

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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 adopt...