The U.S. Internal Revenue Service (IRS) has released the latest regulations on withholding tax and reporting requirements in respect of the transfers of interests (with consideration) in publicly traded partnership (PTP) by non-U.S. persons pursuant to Section 1446(a) and (f) of the Internal Revenue Code. The regulations, which will take effect on 1 January 2023, require qualified intermediaries to, subject to permitted exceptions, be subject to major obligations to withhold and deduct 10% of amount realized as tax, based on the total transaction value when non-U.S. investors conduct sales, trades or other transfers, such regulations may also apply to dividend distributions; in other words, when non US-persons (e.g., Taiwanese investors) sell / trade / transfer interests in PTP, effective from 1 January 2023, 10% of the total transaction amount shall be deducted as tax. This is a major revision of the regulations, and please pay attention to the impact on your own rights and interests. The Company recommends that you consult your tax advisor about the impact.
If you are a client holding interests in PTP, the Company recommends that you review the relevant positions and consider re-allocation of assets before 31 December 2022, in order to cope with the potential impact of holding such securities after 1 January 2023.
Under the premise that the regulations remain unchanged, the Company will stop accepting the purchase of interests in PTP from 1 November 2022, and continues to plan, evaluate the possibility of prohibiting the sale, trade or other transfer (with consideration) of interests in PTP from 2023 onwards, including any excepted trades listed in the regulations, the detailed implementation date will be announced separately.
For relevant regulations, please refer to:
The above announcement is made in accordance with the current IRS relevant laws and regulations, the content may change due to changes in the content of the IRS regulations or changes in the implementation date. The Company will endeavor to provide timely information for reference, but investors should still in respect of their investment positions pay attention to the development of relevant laws and their impact on their own rights and interests.
Sorry for the inconvenience caused.
Yuanta Securities (Hong Kong) Company Limited