June 18, 2013: Details on the Format of the Global Intermediary Identification Number (GIIN)
Foreign Account Tax Compliance Act (FATCA)
IRS comments reveal additional details on the format of the global intermediary identification number
Recent IRS comments at a conference hosted by the Economic Co-operation and Development (OECD) Business and Industry Advisory Committee (BIAC) have shed light on the format of a Foreign Financial Institution’s (“FFIs”) Global Intermediary Identification Number (“GIIN”). FFIs must register with the IRS to obtain a GIIN and agree to certain administrative, documentation, withholding, and reporting requirements to avoid a 30 percent withholding tax on U.S. source income beginning January 1, 2014. The withholding tax expands to gross proceeds and foreign passthru payments beginning January 1, 2017. The IRS has previously released the format of the GIIN, but the recent IRS comments provide additional examples that help decipher the meaning of each of the four parts of the ID.
According to the IRS, the GIIN helps identify a financial institution as FATCA compliant to withholding agents; allows for easy identification of a financial institution’s FATCA type, category, and country; associates each entity with other affiliates/branches in the same affiliated group; and allows for easy identification of an entity on the IRS FFI List. The following details were revealed in their examples and in past guidance:
- The first 6 alphanumeric characters are randomly generated and will be the FATCA ID for an entity. The FATCA ID will also be used as the entity’s log in ID to access the online portal and will be same for all members in an expanded affiliated group.
- The next 5 digits will either be
- All 9’s for a single member FFI (no expanded affiliated group);
- All 0’s for a Lead FFI (entity that sets up the account for the group) or a Sponsoring FFI (entity that sponsors other FFI(s) and agree to perform all required FATCA duties on behalf of the sponsored FFI(s)); or
- A number indicating the order in which the FFI member registered compared to others in the group (e.g., if the member is the 55th entity to register in the group, its number is “00055”).
- The next two letters indicate the financial institution or branch category (i.e., ME for member, LE for lead, BR for branch, SL for single, and SP for sponsor).
- The final three digits are the ISO numeric code for a financial institution’s country of tax residence (e.g., 724 for Spain).
This new information should help withholding agents better understand the format of the GIIN and how they will need to update systems to incorporate and validate the new data element. The validation requirement is particularly important because withholding agents must validate the GIIN against a published IRS list and revalidate GIIN on a yearly basis to ensure any changes are identified. Unfortunately, the comments are not official guidance; however many of the details have been previously published and are in line with the IRS’ comments.
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