As a means to help counter tax evasion from the United States, the United States Internal Revenue Service (the "IRS") introduced in 2001 the Qualified Intermediary Agreement ("QIA"). It is the first agreement that linked non-U.S. banks and other financial intermediaries of the whole word to the IRS, via a withholding tax regime (hereafter referred to as the "QI Regime"). A revised edition of the QIA has been introduced in 2014.
The QI Regime is a simplified scheme of taxation and declaration of revenues derived from U.S. securities ("U.S revenues") received by a private person via a non-U.S. financial intermediary and aims to, firstly, identify nonU.S. Persons and, secondly, apply the correct conventional tax rate on the U.S. revenues received by non-U.S Persons.