27.01.2023 2'

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.

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As informed in our previous information QIs will be required to renew their QI Agreements via the QI Application and Account Management System (QAAMS) until March 31, 2023. Once renewed, the new QI Agreement will be considered retroactively in force from January 1, 2023 and will expire on December 31, 2028.

As the majority of QIs were not able to renew since the necessary link to do so was not available in the QAAMS, on January 20, 2023 the IRS extended the time to renew the QI Agreement until May 1, 2023 and announced that they were aware of the problems and working to solve them. Once we have knowledge that the system is fully working again and/or if the IRS informs that the issues have been resolved, we will send out a separate information.

Renewal of the FFI Agreement

The IRS confirmed that presently the FFI Agreement does not have to be renewed.

Although the current FFI Agreement states that it expires on December 31, 2018, the IRS extended its validity period to December 31, 2022 in the past via announcement. To extend this period again, the IRS announced on December 12, 2022 via its FATCA FAQ that for participating FFIs (and Reporting Model 2 FFIs) the FFI Agreement will remain valid until the earlier of December 31, 2023, or the publication of another revenue procedure that supersedes all or part of the current FFI Agreement (Rev. Proc. 2017-16).

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09.01.2026 19'

2026 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.
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23.12.2025 6'

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.
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23.09.2025 5'

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.
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