1. Can a Gibraltar-managed discretionary trust holding a diversified portfolio of bonds, opt out of being a Paying Agent Upon Receipt to be treated as a collective investment?
Yes No Only if above debt claim threshold

  1. What is least consequential impact of a Paying Agent Upon Receipt opting to be treated as a collective investment?
Settlor is not deemed as beneficial owner Delays applying savings tax until actual distribution Can take advantage of debt claim threshold exemption

  1. Is a preference dividend paying 5% p.a. in scope?
Yes No Only if its cumulative

  1. Is a 10-year certain annuity regarded as an insurance benefit?
Yes No Only if payments commence less than 5 years after subscription

  1. Must an Andorran Council who establishes foundations exclusively for Latin American residents, keep track of interest secured for savings tax purposes?
Yes No If founder is deceased

  1. Which components of a private interest rate swap between two parties are in scope?
The net flow None The fixed rate flow

  1. In a contracting State which has elected the de minimis threshold for Paying Agents Upon Receipt, is a trust holding 10% of its assets in debt claims immediately in scope when it increases that proportion to 25%?
Yes Only on income secured immediately after breaching the threshold No

  1. A capital redemption bond is a policy issued by a life insurance company without any lives insured. Does it therefore escape the definition of interest?
Only if actual performance is linked to less than 25% interest Yes No

  1. Are 3% p.a. protection payments for a credit default swap in scope?
Yes No Only if the derivative is funded

  1. Must a Gibraltar-managed Paying Agent Upon Distribution report to their Competent Authority of their change in place of management to Bermuda?
Yes No Only if future potential beneficiaries are EU residents

  1. A Luxembourg hedge fund, a Jersey-managed life interest trust and an Irish life insurance policy all hold the identical portfolio of 50% bonds and 50% equity. Which is the least likely to be subject to savings tax?
Fund Trust Insurance policy

  1. Can a fund regarded as a Paying Agent Upon Receipt opt out to be treated as a fund?
Only if it is a non-legal non-UCITS Yes No