AEoI Services

As the world becomes increasingly globalised, companies are required to cooperate across borders to ensure that taxpayers adhere to tax regulations. Following the introduction of Common Reporting Standards (CRS) in 2013, financial institutions across the globe are compelled to classify themselves, identify their financial accounts, identify reportable persons and report financial account information on an annual basis to evidence the prevention of tax evasion. The information is then exchanged between participating tax authorities across the relevant jurisdictions.

What we do and how we can help (Our Solutions)

At WTS Hansuke, we leverage extensive industry experience to provide leading-edge AEoI support to financial institutions. Utilising our strong methodologies and technical expertise, we effectively ensure firms’ reporting processes are properly established, implementing due diligence procedures to document and identify reportable accounts.

Our AEoI services include:

• The development of business requirements and remediation of existing systems;
• The design and implementation of firm-wide systems; and
• Practical procedures to identify and report the required information to local tax authorities.

QI Services

The US Qualified Intermediary (QI) regime places obligations on the payers of US-source fixed, determinable, annual and periodic income to identify and document their customers under a contract with the US Internal Revenue Service (IRS). Entering into a QI Agreement with IRS places obligations on financial institutions to ensure procedures are in place to monitor and act on changes in customer circumstances, review the overall effectiveness of their controls, and certify these to the IRS.

What we do and how we can help (Our Solutions)

At WTS Hansuke, our expert team draws on their practical experience of conducting QI periodic reviews and remediations over many years. We assist FS firms in developing governance around ongoing compliance procedures and to meet reporting and certification obligations for the IRS. We emphasise the holistic compliance approach, requiring an analysis of QI policies, procedures, and controls. 

Our QI compliance programme includes:

• Registering a QI with IRS;
• Training and ongoing support for Responsible Officer (RO);
• Establishment of internal control processes and governance;
• Development of QI policies and procedures;
• Periodic Reviews (PRs) and Interim Compliance Reviews (ICRs);
• Reviewing tax withholding statements and reporting documentation;
• Training of QI operational staff (including documentation and reporting); and
• RO certification support.

RFS Services

UK individual investors in non-UK funds are taxable on their investment gains in two contrasting ways, at rates of either 20% or 45%. The lower tax rate is only available to individual investors in funds which have elected into UK’s tax reporting regime, known as Reporting Fund Status (RFS). Institutional investors, including funds of funds, may also benefit from RFS; the application for RFS has a profound impact on post-tax investment returns for UK investors.

What we do and how we can help ( Our Solutions)

At WTS Hansuke, our tailored solutions support clients through RFS procedures, ensuring a swift and efficient compliance process. Our structured, client-centric approach enables the provision of appropriate RFS guidance in both qualifying for RFS status and subsequent annual submission of accounts to HMRC for audit.

Securities Tax Services

All financial institutions will at some point engage in dealings in capital markets securities. Tax authorities have increased their scrutiny of securities transactions. Securities taxes are often imposed on notional principal values rather than spreads or net profits. Understanding and managing task risks associated with securities is an essential element of a financial firm’s risk management function.

What we do and how we can help ( Our Solutions)

At WTS Hansuke, our world-class team of securities, finance, and derivatives tax experts leverage years of experience to assess and design tax robust platforms. Our team support leading sovereign institutions, broker-dealers, securities lending agents, asset managers and custodians. 

Our Security Taxation services include: 

• Security Lending Advisory (SLA); 
• Designing and implementing best-in-class withholding tax management systems;
• Supporting (and outsourcing) reclamation of withholding taxes; 
• Assistance with negotiating taxation terms within market agreements and SLAs; 
• Multi-jurisdictional reviews for new markets and new investments/instruments; 
• Securing robust FIN48/IRFIC23 opinions covering the treatment of market transactions and capital gains; 
• Analysis of securities financing transactions, including rehypothecation and beneficial ownership reviews; 
• Analysis of give-up trades via FIX and other DMA technology; 
• Negotiating with taxation authorities where non-compliance has inadvertently occurred.