2025 Year Wrap-up and Outlook
While CRS 2.0 will enter into force as scheduled on 1 January 2026, the entry into force of the Swiss CARF provisions has been postponed until at least 2027. As a result, both CARF reporting and due diligence obligations are deferred, providing affected financial institutions with additional time for preparation. At the same time, further regulatory developments are coming into focus, including the revised FATCA agreement (expected to enter into force no earlier than 1 January 2027), new electronic filing requirements in the QI environment, and the postponed introduction of the German MiKaDiv reporting obligations by the end of 2026.
Approval of PQS as authorized 1042 e-Filer and Upcoming e-Filing Obligations
Due to the upcoming changes in the e-filing obligations of the Form 1042, PQS applied for the required status as Electronic Return Originator and Transmitter with the IRS to be able to file Form 1042 and its attachments electronically via the Modernized e-File Platform (MeF) and has recently attained this status.
With this newsletter, we would like to inform you about the significant changes in the e-filing obligations of the Forms 1042 and 1042-S, which will have an impact on all filers such as Qualified Intermediaries (“QIs”), Qualified Derivatives Dealer (“QDDs”) and Withholding Foreign Partnerships (“WFPs”) as well as our new e-filing service for Form 1042 and its attachments.
Extension of International Automatic Exchange of Information in Tax Matters (CRS 2.0)
In 2022, the OECD published the updated Standard for Automatic Exchange of Financial Account Information in Tax Matters, also referred to as the Common Reporting Standard (CRS), including the amendment of the existing standard for the automatic exchange of financial account information (so-called CRS 2.0) and the introduction of the new Crypto-Asset Reporting Framework (CARF). This newsletter includes the most significant changes to the legislation planned to enter into force on January 1, 2026.
New message format requirement for international tax payments to the U.S. Treasury
We would like to inform international taxpayers and especially Qualified Intermediaries with primary withholding responsibility (“Primary QIs”), Qualified Derivatives Dealer (“QDDs”), Withholding Foreign Partnerships (“WFPs”) and Withholding Foreign Trusts (“WFPs”) about the new message format requirement for remitting tax payments to the U.S. Treasury.
Notice 2024-44 and Form 1120-F
With our Newsletter Notice 2024-44 and Form 1120-F we would like to inform about the extension of the phase-in period for certain rules under Section 871(m), 1441, 1461 and 1473 of the Internal Revenue Code (the "Section 871(m) Regulations") and remind our QDD clients of the filing of Form 1120-F.
CRS Reporting Reminder 2025
Since the deadlines for filing the CRS reporting are approaching, we would like to inform all reporting financial institutions on their CRS reporting requirements and some specific updates relevant for the tax year 2024.
2025 Reporting Reminder
We would like to inform all Swiss financial institutions on their reporting requirements under CRS, FATCA and QI.
The QI Reporting Requirements outlined in this newsletter will also be applicable to non-Swiss QIs. For the non-Swiss CRS and FATCA reporting requirements, the respective local implementation guidance must be consulted.
QI Update
With this newsletter, we would like to inform the Swiss QIs/FFIs on the most relevant regulatory updates.
Switzerland Changes to Model 1 FATCA IGA
On June 27, 2024, the Swiss State Secretariat for International Finance (SIF) announced the signing of a new Intergovernmental Agreement (IGA) under the Foreign Account Tax Compliance Act (FATCA) between Switzerland and the USA. Scheduled to take effect on January 1, 2027, this new FATCA IGA is a reciprocal Model 1 IGA.
CRS Reporting Reminder 2024
Since the deadline for filing the CRS reporting is approaching, we would like to inform all Swiss financial institutions on their CRS reporting requirements and some specific updates relevant for the tax year 2023.
2024 Reporting Reminder
We would like to inform all Swiss financial institutions on their reporting requirements under CRS, FATCA and QI.
The QI Reporting Requirements outlined in this newsletter will also be applicable to non-Swiss QIs. For the non-Swiss CRS and FATCA reporting requirements, the respective local implementation guidance must be consulted.
QI: 2023 Year Wrap-up and Update
Another eventful year is about to be over, which means it is time for us to take a look back at all that happened in the Qualified Intermediary space this year and to inform about what is going to happen next year.
PEQ Solutions is now PQ Solutions
We would like to inform you that the former PEQ Solutions LLC has recently changed its name to PQ Solutions LLC. As part of this change, we have updated our company logo and corporate design to reflect the new name and our website URL has changed to pqs.ch.
FIRE System Update (2)
The IRS recently announced eagerly anticipated relief regarding accessing the Information Returns Application for Transmitter Control Code (IR-TCC) System, as well as the File Information Returns Electronically (FIRE) System, and also informed about other platforms that will be used by filers in the future.
CRS Reporting Reminder 2023
Since the deadline for filing the CRS reporting is approaching, we would like to inform all Swiss financial institutions on their CRS reporting requirements and some specific updates relevant for the tax year 2022.
New Login Process for QIs
With this short update we would like to inform all QIs on the new login process for the QI Application and Account Management System.
Update QI Agreement Renewal
With this short update we would like to inform all QIs that have not renewed their QI Agreements yet on the most recent updates regarding the renewal process.
QI Agreement Renewal
With this information we would like to inform that the link for the renewal of the QI Agreement is now universally available in the QAAMS.
QI Agreement Renewal Time Extension
With this information we would like to quickly update readers about the renewal of the QI Agreement and the extension of the FFI Agreement.
Reporting Reminder 2023
We would like to inform all Swiss financial institutions on their reporting requirements under CRS, FATCA and QI.
Final 2023 QI Agreement and Section 1446(f) Update
With this information we inform in detail about the changes made to the final version of the new 2023 QI Agreement compared to the proposed QI Agreement published earlier this year, and some last minute announcements the IRS made with respect to Section 1446(f).
Section 1446(f) and New QI Agreement
With this information we inform about the upcoming Section 1446(f) regulation and the upcoming changes to the QI Agreement, which will enter into force on January 1, 2023. Readers will get an extensive overview over the upcoming changes and will be able to determine if and how the new regulation affects them.
QAAMS New Sign-In System
With this information we would like to inform about the upcoming, modified sign-in options for new users of the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application and Account Management System (QAAMS).
Section 871(m)
With this information we would like to inform about the extension of the phase-in period for certain rules under Section 871(m), 1441, 1461 and 1473 of the Internal Revenue Code (the “Section 871(m) Regulations”).
FIRE System Update
With this extensive information we would like to inform about the changes made to Form 4419, the updates to the FIRE system, the new IR-TCC system introduced by the IRS, and the proposed and possible solutions to the challenges resulting from the changes.
FATCA Group Request Reminder
Swiss financial institutions are advised to ensure the accuracy of their FATCA reporting from 2014 to 2021, prepare required information and documents promptly for submission to the SFTA, and test information exchange procedures ahead of potential group requests, as the USA can now make such requests under the Swiss-US FATCA IGA, with a strict ten-day deadline for compliance.
CRS Reporting Reminder 2022
Since the deadline for filing the CRS reporting is approaching, we would like to inform all Swiss financial institutions on their CRS reporting requirements and some specific updates relevant for the tax year 2021.
Reporting Reminder 2022
We would like to inform all Swiss financial institutions on their reporting requirements under CRS, FATCA and QI. The QI Reporting Requirements outlined in this newsletter will also be applicable to non-Swiss QIs. For the non-Swiss CRS and FATCA reporting requirements, the respective local implementation guidance must be consulted. As in previous years, PQS will be able to support FIs with preparing and uploading FATCA, QI and CRS reportable data to the respective authorities.
