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Norway and Spain Intergovernmental Agreements - 31/05/2013


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Norwegian IGA

On April 15, 2013, Norway and the United States signed an Intergovernmental Agreement (“IGA”) to improve international tax compliance with respect to FATCA.

In addition to the IGA, the country entered into a separate memorandum of understanding (“MOU’) to further clarify language in the IGA. The agreement is substantially similar to other Model 1 agreements signed in Europe by the United Kingdom, Ireland, and Denmark and includes reciprocal reporting obligations for the United States.

Similar to the Irish, Danish, and Mexican IGAs, the U.S. is committing to creating rules to require the collection and reporting of the Norwegian taxpayer identification number (“TIN”, the Norwegian personal identification number or organization number) for Norwegian residents (along with other information) as opposed to the date of birth for U.K. residents.

For additional details, please find enclosed the news alert prepared by our US colleagues highlighting the main aspects of this agreement.

Spanish IGA

On May 14, 2013, Spain and the United States signed an IGA to improve international tax compliance with respect to FATCA.

The agreement is substantially similar to the other Model 1 IGAs released to date including reciprocal reporting obligations for the United States. However, minor updates where made to Annex 1 including allowing 90 days for a Reporting Spanish Financial Institution (FI) to document a preexisting account holder that no longer meets a documentation de minimis threshold at the end of a prior calendar year (e.g., account previously excepted from review because the aggregated account balance or value is USD 50,000 or less but later exceeds USD1,000,000 at the end of a calendar year requiring additional due diligence review).

As for the agreement with Norway, the news alert prepared by our US collegues provides further details on the agreement.

If you have any queries regarding the above, please do not hesitate to contact us.

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