Operational Information

Relief at source - eligibility, documentation - U.S.A. - CFCL (VestimaPRIME Clients)

Asset Services | Tax | USA CFCL

Reference

Service level
CFCL
Last Updated
23.09.2025

Who can obtain relief at source?

Tax relief at source on US taxable income from U.S. VestimaPRIME fund securities is available through Clearstream Fund Centre, if and only if Clearstream Fund Centre’s direct client has certified his account at account opening by providing a withholdable statement and provided that:

  1. Clearstream Fund Centre’s direct client is the final beneficial owner, FATCA compliant and resident in a country which has signed a Double Taxation Treaty (DTT) with the USA, or
  2. Clearstream Fund Centre’s direct client is a U.S. exempt person, or
  3. Clearstream Fund Centre’s direct client is a Qualified Intermediary (QI) that assumes primary nonresident alien (NRA) withholding responsibility and Form 1099 and back-up withholding responsibility (QIA), or
  4. Clearstream Fund Centre’s direct client is a QI that assumes primary NRA withholding responsibility but does not assume Form 1099 and back-up withholding responsibility (QIB), or
  5. Clearstream Fund Centre’s direct client
    - is a QI that does not assume primary NRA withholding responsibility, but that assumes Form 1099 and back-up withholding responsibility (QID) and
    - holds the U.S. source securities on behalf of FATCA compliant recipient being non-U.S. beneficial owners that are residents in a country that has signed a DTT with the U.S.A. and/or US persons or
  6. Clearstream Fund Centre’s direct client
    - is a QI that does not assume primary NRA withholding responsibility nor Form 1099 and back-up withholding responsibility (QIC) and
    - holds the securities on behalf of FATCA compliant recipient being non-U.S. beneficial owners that are residents in a country that has signed a DTT with the U.S.A. and/or US exempt persons and/or US specified persons in a payee pool and/or US specified persons for which a 1099 reporting is required.

For the avoidance of doubt, the following type of clients are not eligible to subscribe to VestimaPRIME US taxable securities:

Clearstream Fund Centre’s direct client:

  • is a FATCA compliant Non-Qualified Intermediary (NQI) and holds the securities (either directly or indirectly via a an additional FACTA compliant NQI intermediary) on behalf of recipients that are FATCA compliant final beneficial owners that are residents in a country that has signed a DTT with the U.S.A. and/or FATCA compliant Qis and/or US exempt recipient and/or US specified persons in a payee pool and/or US specified persons for which a 1099 reporting is required
  • is a Non-Financial Foreign Entity (NFFE)

Documentation requirements

To access tax relief at source for U.S. VestimaPRIME fund securities, clients with certified accounts are not required to submit any additional documentation.

Clients are required at account opening to provide a valid and last up to date:

  • IRS form (W8 and/or W9)
  • Withholding statement

Important note:

If the client intends to invest into an investment fund that generates ECI (effectively connected income), then disclosure of the BO details will be required. Failure to provide UBO documentation will lead to Clearstream Fund Centre disclosing the direct investor.