Any financial institution outside of the USA can enter into a QI agreement
with the IRS if it meets the requirements. A financial institution can include a
depository institution, a custodial institution, investment entities and certain
types of insurance companies.
The QI regime is a relief at source model implemented by the USA. It allows financial institutions outside of the USA to enter into a QI agreement with the IRS enabling the financial institution to grant relief at source on USA withholding taxes to its clients.