This chapter explains the structure of the US withholding taxwithholding tax space when applied in a cross-border environment, including notably those that choose not to adopt QIQualified Intermediary (QI) status. We will define the actors in the payment chain and their roles, together with an explanation of the options available to financial institutions including, notably, nonqualified intermediary status. Particular attention will be given to summarising the differences between the 2017 QI agreement and the 2023 QI Agreement.

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Regulatory Structure

  • Ross K. McGill,
  • Kirsty V. Pitkin

摘要

This chapter explains the structure of the US withholding taxwithholding tax space when applied in a cross-border environment, including notably those that choose not to adopt QIQualified Intermediary (QI) status. We will define the actors in the payment chain and their roles, together with an explanation of the options available to financial institutions including, notably, nonqualified intermediary status. Particular attention will be given to summarising the differences between the 2017 QI agreement and the 2023 QI Agreement.