27.01.2023

2'

QI Agreement Renewal Time Extension

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).