Taxes Consolidation Act 1997 section 172E

Qualifying intermediaries

Section 172E sets out the conditions under which an intermediary may be authorised as a qualifying intermediary (QI) for the purposes of dividend withholding tax (DWT), and the obligations that attach to that status.

• DWT does not apply to distributions made through a qualifying intermediary for the benefit of non-liable persons, provided the intermediary meets residency, agreement, and authorisation requirements.
• A qualifying intermediary agreement imposes detailed obligations including record retention, compliance reporting, duty of care over declarations, and allowing Revenue verification.
• Revenue may only authorise as a qualifying intermediary a licensed bank (or its wholly owned subsidiary), a member of a recognised stock exchange, or a person Revenue considers suitable.
• A qualifying intermediary authorisation expires after seven years but may be renewed, and Revenue may revoke it at any time for non-compliance or unsuitability.