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Governance advisory
We guide boards and management teams in frameworks, team processes and leadership dynamics to deliver sustainable value.
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Financial services advisory
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Business risk services
Our market-driven expertise helps firms keep growing and manage risk in an evolving regulatory landscape.
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Risk
Meet risks with confidence and transform your business – we support you to manage risk and deliver on your goals.
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Economic consulting
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Government and public sector
Experience and expertise in delivering quality public sector advisory and audits.
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Business consulting
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Transaction advisory services
Whether buying or selling, we help you get the deal done with our comprehensive range of transaction advisory services.
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Financial accounting advisory services (FAAS)
Our FAAS team can support your finance function with the flexible resource they need to get results.
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Corporate finance advisory
Building a business is never easy. We help you maximise the value of your business and find the right option.
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Valuations
Help to understand or support the valuation of a business or asset.
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Insolvency and global asset recovery
We provide asset tracing and seamless cross-border global recovery for clients.
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Forensic and investigation services
Market-driven expertise in investigations, dispute resolution and digital forensics.
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Restructuring
Our restructuring team help lenders, investors and management navigate contingency plans, restructuring and insolvency.
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Transformation consulting
Is business transformation a priority for your organisation? Our expert insight and guidance can help you achieve it.
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Pensions assurance
A tailored service that responds to evolving risks and regulations.
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Accounting services
Optimise your growth with expert accounting services. Contact us today.
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Royalty and intellectual property (IP) audits
Enhance IP asset protection with our royalty and IP audit services. Expertise in licensing, revenue detection, and compliance improvements.
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Business consulting
Partnering with you to deliver sustainable business change that helps you realise your ambitions.
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Corporate Simplification
Release value, reduce compliance complexity, and improve tax efficiency by streamlining your group structure.
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Economic consulting
Bespoke guidance grounded in complex economic theory and practical sector insight to help you make the right decisions.
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Financial accounting advisory services (FAAS)
Our FAAS team can support your finance function with the flexible resource they need to get results.
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Governance advisory
We guide boards and management teams in frameworks, team processes and leadership dynamics to deliver sustainable value.
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International
Unlock global opportunities with our local expertise and worldwide reach.
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People advisory
Driving business performance through people strategy and culture.
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Strategy Group
Successful business strategy is rooted in a clear understanding of the market, customer segmentation and how purchase decisions vary.
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Respond: Data breach, incident response and computer forensics
Are you prepared for a cyber failure? We can help you avoid data breaches and offer support if the worst happens.
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Comply: Cyber security regulation and compliance
Cyber security regulation and compliance is constantly evolving. Our team can support you through the digital landscape.
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Protect: Cyber security strategy, testing and risk assessment
Cyber security threats are constantly evolving. We’ll work with you to develop and test robust people, process and technology defences to protect your data and information assets.
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Corporate finance advisory
Building a business is never easy. We help you maximise the value of your business and find the right option.
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Debt advisory
Working with borrowers and private equity financial sponsors on raising and refinancing debt. We can help you find the right lender and type of debt products.
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Financial accounting advisory services (FAAS)
Our FAAS team can support your finance function with the flexible resource they need to get results.
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Financial modelling services
Financial modelling that helps you wrestle with your most pressing business decisions.
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Operational deal services
Enabling transaction goals through due diligence, integration, separation, and other complex change.
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Our credentials
Search our transactions to see our experience in your sector and explore the deals advisory services we've delivered.
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Transaction advisory services
Whether buying or selling, we help you get the deal done with our comprehensive range of transaction advisory services.
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Valuations
Help to understand or support the valuation of a business or asset.
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The ESG agenda
Shape your ESG agenda by identifying the right metrics, sustainable development and potential business value impact.
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ESG driven business transition
Whatever your ESG strategy, we can support your organisation as it evolves while maximising efficiency and profitability.
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ESG programme and change management
Do you have the right capabilities to drive the delivery of your ESG strategy to realise your targets?
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ESG risk management
You must protect, comply, understand and influence to successfully manage the risk involved with ESG issues. We can help.
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ESG strategy, risk and opportunity identification
We can help you clearly define your ESG Strategy, with the risks and opportunities identified and managed.
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Create value through effective ESG communication
Building trust and engagement with your stakeholders on your ESG strategy.
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ESG metrics, targets and disclosures
The pressure to report your ESG progress is growing. Do your targets measure up?
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ESG governance, leadership and culture framework
Make the most of ESG opportunities by effectively embedding your strategy across your organisation.
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ESG and non-financial assurance
Support your board to be confident in supplying robust information that withstands scrutiny.
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Transition planning to net zero
Supporting your organisation in the transition to net zero.
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Actuarial and insurance consulting
We consult extensively to the life insurance, general insurance, health insurance and pensions sectors.
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Business risk services
Our market-driven expertise helps firms keep growing and manage risk in an evolving regulatory landscape.
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Financial crime
Helping you fight financial crime in a constantly changing environment
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Financial services business consulting
Leverage our diverse capabilities to manage challenges and take opportunities: from assurance to transformation
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Financial services tax
Helping financial services firms navigate the global financial services and funds tax landscape.
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Regulatory and compliance
Providing an exceptional level of regulatory and compliance to firms across the financial services industry.
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Corporate intelligence
Corporate intelligence often involves cross-border complexities. Our experienced team can offer support.
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Litigation support
Industry-wide litigation support and investigation services for lawyers and law firms.
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Disputes advisory
Advising on quantum, accounting and financial issues in commercial disputes.
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Forensic investigations and special situations
Do you need clarity in an uncertain situation? If you're accused of wrongdoing we can help you get the facts right.
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Forensic data analytics
Our forensic data analytics team are helping businesses sift the truth from their data. See how we can help your firm.
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Monitoring trustee and competition services
Monitoring trustee services to competition, financial and regulatory bodies.
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Financial crime
Supporting your fight against financial crime in an ever-changing environment
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Public sector advisory
To deliver excellent public services, local and central government need specialist support.
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Public sector consulting
Helping public sector organisations maintain oversight of services and understand what's happening on the ground.
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Public sector audit and assurance
As a leading UK auditor, we have unparalleled insights into the risks, challenges and opportunities that you face.
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Contentious estates and family disputes
We manage complex and sensitive disputes through to resolution.
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Digital Asset Recovery
Get guidance and technical expertise on digital finance and cryptoasset recovery from our dedicated crypto hub.
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Grant Thornton Offshore
Grant Thornton Offshore is our one-stop global solution for insolvency, asset recovery, restructuring and forensics services.
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Insolvency Act Portal
Case information and published reports on insolvency cases handled by Grant Thornton UK LLP.
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Litigation support
Industry-wide litigation support and investigation services for lawyers and law firms.
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Personal insolvency
We can support you to maximise personal insolvency recovery and seek appropriate debt relief.
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South Asia business group
Supporting your growth in the UK-India economic corridor and beyond.
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US business group
Optimise your trans-Atlantic operations with local knowledge and global reach.
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Japan business group
Bridging the commercial and cultural divide and supporting your ambitions across Japan and the UK.
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Africa business group
Connecting you to the right local teams in the UK, Africa, and the relevant offshore centres.
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China-Britain business group
Supporting your operations across the China – UK economic corridor.
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Asset based lending advisory
Helping lenders, their clients and other stakeholders navigate the complexities of ABL.
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Contingency planning and administrations
In times of financial difficulty, it is vital that directors explore all the options that are available to them, including having a robust ‘Plan B’.
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Corporate restructuring
Corporate restructuring can be a difficult time. Let our team make the process simple and as stress-free as possible.
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Creditor and lender advisory
Whether you're a creditor or lender, complex restructurings depend on pragmatic commercial advice
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Debt advisory
Our debt advisory team can find the right lender to help you in restructuring. Find out how our experts can support you.
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Financial services restructuring and insolvency
Financial services restructuring and insolvency is a competitive marketplace. Our team can help you navigate this space.
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Pensions advisory services
DB pension-schemes need a balanced approach that manages risk for trustees and sponsors in an uncertain economy.
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Restructuring and insolvency tax
Tax will often be crucial in a plan to restructure a distressed business. Our team can guide you through the process.
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Restructuring Plans
Market leading experience in advising companies and creditors in Restructuring Plan processes.
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Controls advisory
Build a robust internal control environment in a changing world.
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Data assurance and analytics
Enhancing your data processes, tools and internal capabilities to help you make decisions on managing risk and controls.
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Enterprise risk management
Understand and embrace enterprise risk management – we help you develop and connect risk thinking to your objectives.
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Internal audit services
Internal audit services that deliver the value and impact they should.
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Managing risk and realising ESG opportunities
Assess and assure risk and opportunities across ESG with an expert, commercial and pragmatic approach.
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Project, programme, and portfolio assurance
Successfully delivering projects and programmes include preparing for the wider impact on your business.
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Service organisation controls report
Independent assurance provides confidence to your customers in relation to your services and control environment.
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Supplier and contract assurance
Clarity around key supplier relationships: focusing on risk, cost, and operational performance.
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Technology risk services
IT internal audits and technology risk assurance projects that help you manage your technology risks effectively.
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Capital allowances (tax depreciation)
Advisory and tools to help you realise opportunities in capital allowances.
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Corporate tax
Helping companies manage corporate tax affairs: delivering actionable guidance to take opportunities and mitigate risk.
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Employer solutions
We will help you deliver value through your employees, offering pragmatic employer solutions to increasing costs.
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Indirect tax
Businesses face complex ever changing VAT regimes, guidance and legislation. We can help you navigate these challenges.
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International tax
Real-world international tax advice to help you navigate a changing global tax landscape.
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Our approach to tax
We advise clients on tax law in the UK and, where relevant, other jurisdictions.
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Private tax
Tax experts for entrepreneurs, families and private business. For now and the long term.
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Real estate tax
Stay ahead of real estate tax changes with holistic, tax-efficient solutions.
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Research and development tax incentives
We can help you prepare optimised and robust research and development tax claims.
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Tax dispute resolution
We make it simple to stay compliant and avoid HMRC tax disputes
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Tax risk management
We work with you to develop effective tax risk management strategies.
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Skills and training
Get the right support to deliver corporate and vocational training that leads the way in an expanding market.
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Private education
Insight and guidance for all businesses in the private education sector: from early years to higher education and edtech.
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Facilities management and property services
Get insight and strategic support to take opportunities that protect resilience and drive UK and international growth.
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Recruitment
Helping recruitment companies take opportunities to achieve their goals in a market where talent and skills are key.
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Food and beverage (F&B)
We can help you find the right ingredients for growth in your food and beverage business.
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Travel, tourism and leisure
Tap into our range of support for travel, tourism and leisure businesses in this period of challenge and change.
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Retail, e-commerce and consumer products
With multiple challenges and opportunities in the fast-evolving retail sector, make sure you are ready for them.
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Banking
Our expertise and insight can help you respond positively to long term and emerging issues in the banking sector.
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Capital markets
2020 is a demanding year for capital markets. Working with you, we're architecting the future of the sector.
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Insurance
Our experienced expert team brings you technical expertise and insight to guide you through insurance sector challenges.
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Investment management
Embracing innovation and shaping business models for long-term success.
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Pensions
Pension provision is an essential issue for employers, and the role of the trustee is becoming increasingly challenging.
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Central and devolved government
Helping central and devolved governments deliver change to improve our communities and grow our economies.
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Infrastructure and transport
Delivering a successful transport or infrastructure project will require you to balance an often complex set of strategic issues.
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Local government
Helping local government leverage technical and strategic expertise deliver their agendas and improve public services.
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Regeneration development and housing
We provide commercial and strategic advice to assist your decision making in pursuing your objectives.
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Health and social care
Sharing insight and knowledge to deliver transformation and improvement to health and social care services.
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Charities
Supporting you to achieve positive change in the UK charity sector.
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Education and skills
The education sector has rarely faced more risk or more opportunity to transform. You need to plan for the future.
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Social housing
We are committed to helping change social housing for the better, and can help you make the most of every opportunity.
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Technology
We work with dynamic technology companies of all sizes to help them succeed and grow internationally.
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Telecommunications
Take all opportunities to realise your goals in telecommunications: from business refresh to international expansion.
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Media
Media companies must stay agile to thrive in today’s highly competitive market – we’re here to support your ambitions.
On 13 December 2022 the IRS and Treasury Department released Revenue Procedure 2022-43 (the 2023 QI Agreement). Revenue Procedure 2017-15 (2017 QI Agreement) has now been superseded by the 2023 qualified intermediary (QI) Agreement with respect to QI obligations effective 1 January 2023. All QIs are required to renew the QI agreement via the IRS portal by 1 May 2023, relating to a technical issue with the Qualified Intermediary Application and Account Management Systems (QAAMS).
The majority of the updates in the 2023 QI Agreement relate to the 1446(a) and (f) compliance obligations regarding PTPs, and specific qualified derivatives dealers (QDD) and QSL updates, but there are some other important changes that impact all QIs.
Responsible officer certifications
The requirement to reconcile Form 1042 and 1042-S
As part of the three yearly periodic certification, all QIs will have to provide reconciliation information of Form 1042 and 1042-S (including amended forms) for each year of the certification period. The information will have to be uploaded as an attachment on the QAAMS. That's in contrast to the current requirement to only provide a reconciliation for the year subject to periodic review.
Certification-related information that QIs must provide at the end of each certification period
Unlike the 2017 QI Agreement, the 2023 QI Agreement mandates that all QIs upload the periodic review report at the time of periodic certification.
Deadline for completion of periodic certifications
A QI that chooses the third year of the certification period to undertake the periodic review was required to submit its periodic certification by 31 December of the year following the end of the certification period. Under the 2023 QI Agreement, it's now possible for the QI to seek a possible extension to this date, subject to IRS agreement.
Documentation
Validity standards for documentation
The validity of treaty claims as described in FAQs one and two of the QI Withholding Foreign Partnership (WP) and Withholding Foreign Trust FAQs has been incorporated in the 2023 QI Agreement. For accounts opened from 1 January 2018, where a withholding certificate contains a US mailing or permanent address, the QI may rely on documentary evidence provided by the account holder for treaty purposes only where it holds a permanent residence address in the jurisdiction of the treaty claim.
Reporting
Furnishing recipient-specific Form 1042-S to account holder
Under the 2017 QI Agreement, where a QI has over withheld and didn't apply the collective refund procedure, the QI is required to provide a recipient-specific Form 1042-S to the account holder. The 2017 QI Agreement didn't provide a time limit for when an account holder can request a recipient-specific Form 1042-S. Under the 2023 QI Agreement, however, an account holder must now request a Form 1042-S within two years from the year of payment, and where the payment is subject to section 1446(a) or (f), the time limit for a request has been extended by a year to three years from the year of payment. The account holder must also provide a US TIN to make such a request. The additional year granted for payments subject to 1446(a) and (f) is intended to provide the account holder additional time to file their own US income tax return.
1446(a) and (f) requirements
The proposed requirements contained in Notice 2022-23 have been largely incorporated within the 2023 QI Agreement. However, the IRS has modified some of the requirements due to concerns raised by stakeholders with respect to disclosing QIs, partner reporting and documentation validity.
The best effort to obtain US TIN
The 2023 QI Agreement now includes a 'best efforts' solicitation requirement to obtain a US TIN from account holders who hold PTP interests. The prescribed requisition procedures must be followed to maintain the validity of withholding certificates from foreign partners. The 'best efforts' provision will enable disclosing QIs to maintain their status for the entire amount of payment despite not providing a US TIN for an account holder. This allowance, however, doesn't relieve the responsibility of a QI to obtain a US TIN to apply a reduced rate of withholding.
Disclosing QIs
QIs acting as a disclosing QI – a QI that doesn't assume either primary withholding or pooled reporting responsibility – must provide payee-specific documentation for the entire amount of a PTP distribution or the amount realised from the sale of PTP interest. Under the proposed requirements, a disclosing QI wasn't able to act as a disclosing QI for the entire amount of a payment made to multiple account holders where any account holder failed to provide its US TIN despite the QI’s effort to obtain a TIN. Under the 2023 QI Agreement, the requirement for a US TIN on a Form W-8 has now been relaxed as long as the QI complies with the best efforts requirement.
Partner reporting - nominee holding a PTP interest
Under the proposed requirements, all QIs not acting as disclosing QI were required to issue the account holder with a written statement (or statements) that corresponded to the information that the PTP would have provided the account holder on a Schedule K-1. This has now been amended under the 2023 QI Agreement to allow for a QI (that isn't acting as a disclosing QI) to provide the account holder with the Schedule K-1 issued by the PTP to the QI as well as certain allocation information.
Disclosing QIs would have been required to provide a written statement (or statements) to their nominee that corresponds to the information that the PTP would have provided the account holder on Schedule K-1. Under the 2023 QI Agreement, provided the disclosing QI maintains fully segregated and disclosed accounts with the nominee, the disclosing QI isn't required to provide such a written statement.
Notice 2023-8
The Treasury Department and the IRS released Notice 2023-8 (Notice) confirming US regulations will be amended shortly such that where entities are organised outside of the US and trade only on a non-US stock market the broker may presume the entity isn't a PTP for US tax purposes and hence not be required to withhold. However, the relief is subject to the absence of actual knowledge by the broker that the entity is a PTP for US tax purposes (unless the PTP provides a qualifying notice). The Notice also extends relief from withholding to short sales of PTPs subject to limitations. Brokers may rely on the Notice before the final regulations are released. The relief may also be availed of by QIs subject to the 2023 QI Agreement.
Qualified derivatives dealers and qualified securities lenders
The 2023 QI Agreement reflects other recent IRS announcements (including Notice 2022-37) to defer certain provisions contained within Section 871(m) of the IRS regulations and the consequential impact on QIs that have elected to be a QDD / QSL. For example, periodic reviews for QDDs won't be required in 2023 or 2024, although QDDs will be required to certify they made good faith efforts to comply with Section 871(m) regulations and the 2023 QI Agreement.
To find out more about operational tax risks and opportunities, get in touch with Martin Killer
We offer a full range of tax services to help financial services businesses to optimise their tax position, manage tax risk and meet tax compliance obligations.