Revenue Note for Guidance
This section provides special measures to deal with the common situation where distributions are made through a qualifying intermediary who is also a recognised clearing system.
To be a recognised qualifying intermediary, a person must be a qualifying intermediary that is also a recognised clearing system within the meaning in section 246A(2)(a) or a person wholly owned by a recognised clearing system, within the meaning in section 246A(2)(a).
Since a recognised qualifying intermediary, must be a qualifying intermediary it must
In addition, the intermediary must
A recognised qualifying intermediary is subject to the obligations of a qualifying intermediary as set out in the guidance notes to section 172F.
(1) A number of conditions must be satisfied if a person is to be a recognised qualifying intermediary. Firstly, the person must be a qualifying intermediary and must therefore satisfy the conditions to be a qualifying intermediary as set out in the guidance notes to section 172E. Secondly, the person must also be a recognised clearing system, within the meaning of section 246A(2)(a) or a person who is wholly owner by a recognised clearing system, within the meaning in section 246A(2)(a). These systems are listed in the definition in section 246A.
(2) DWT does not apply where relevant distributions are received by a recognised qualifying intermediary and paid to an authorised withholding agent or another recognised qualifying intermediary, so long as the recognised qualifying intermediary has obtained a notice in writing from the authorised withholding agent or the other recognised qualifying intermediary that it is an authorised withholding agent or a recognised qualifying intermediary in relation to those distributions.
Relevant Date: Finance Act 2021