KPMG offers your organization different services and tools to meet the Qualified Intermediary Compliance requirements, which will be audited in 2021 with respect to financial year 2020.

Most financial institutions that have a QI agreement in place with the IRS will be subject to a QI review in 2021, for the calendar year 2020 (the last calendar year of the certification period 2018-2020).

As 2020 will become a decisive year to make sure that your financial institution meets the compliance requirements of section 10 of the QI agreement, the Financial Services Tax team at KPMG Belgium invites you to get in touch to explore the different services and tools we can provide you with.


Financial institutions are required to organize regular training for all employees working on Qualified Intermediary (QI) activities. The scope of this obligation includes not only tax advisors, but also wider operational back-office functions. KPMG Belgium offers you two solutions to help the QI responsible officer at your organization to meet this requirement:

— In-house training whereby a QI expert provides a tailor-made presentation of approximately 3 hours, focusing on the specific characteristics of your institution (e.g. primary or secondary QI status).These in-house training sessions always lead to an interactive presentation, whereby we take the time to immediately respond to any questions that arise. Budget-wise, an in-house training session allows your organization to invite all staff members involved with QI at a much lower cost than an external training.

— To offer an alternative to in-house training, KPMG has also launched a new eLearning tool on QI. Your employees can boot up their computer wherever they are, and dive right into the training on-the-go, and at their own pace. The QI eLearning course covers all the main obligations, including identification of clients, withholding, and reporting. If you are the QI responsible officer, the final test results will come straight to your inbox. This should give you the assurance you need that the QI rules have been fully digested by each employee.

QI Health Check (pre-audit)

In order to verify whether your financial institution is ready to successfully undergo the official QI review for the 2020 calendar year, we advise you to organize a preliminary health check in Q2 2020.

Together with your QI specialists, KPMG can define a tailor-made health check program whereby we review the compliance with documentation-, withholding- and reporting formalities, taking into account the official QI review criteria. Based on the outcome of the health check we can advise and assist you in modifying your internal procedures or implementing an internal verification program whereby certain assumptions are tested on a regular basis by way of queries on the client data.

Why perform a health check if our latest QI review results were satisfactory?

As the official review is mostly limited to a data sample of one specific year of each three subsequent calendar years, it is possible that client documentation, IT systems and staff members have changed, which can lead to non-compliance with internal procedures.

Can a health check provide insights that we don’t already have as result of the official QI review?

Yes, by selecting a balanced sample we can discover shortcomings which do not necessarily show up in the official QI review, because the number of certain types of clients (e.g. civil partnerships) is too limited within the entire QI client population.

The QI Consistency Exercise

Due to Automatic Exchange Of Information (AEOI) regulations, financial institutions have gathered huge volumes on tax-related personal data of their customers. That amount of information should be in line with the QI client identification information. QI can no longer be seen as a separate withholding regime, but should be integrated within a FATCA and CRS context.

The QI Consistency Exercise will help your organization to manage data consistency as part of your QI compliance framework.

Some examples:

  • Consistency between FATCA & QI foreign status.
  • Integration of CRS data to determine the QI treaty status of a client.
  • Integration of CRS information as a FATCA and so QI indicium.
  • Alignment with Belgian operational taxes and exchange under the CAP where applicable.


Reach out to us today to discover how we can help you meet the Qualified Intermediary Compliance requirements.

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