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”)...
Multiple jurisdictions have been and continue to converge their taxation frameworks to eradicate cross-border tax evasion and establish common prin...
