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

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 m...