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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.

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.

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.