04.17 – Tax Identification Numbers (TINs)

Where it has been established that an account holder is a US Person, a Financial Institution is required to obtain a US TIN in several instances. When referred to, a US TIN means a US Federal Taxpayer Identifying Number.

For Pre-existing Individual Accounts that are Reportable Accounts, a US TIN need only be provided if it held by the Reporting Financial Institution. In the absence of a record of the US TIN, a date of birth should be provided, but again only where that is held by the Reporting Financial Institution.

In line with the Agreement, HMRC has introduced legislation to require Reporting Financial Institutions to obtain the US TIN for relevant Pre-existing Accounts from 1 January 2017.

For all New Individual Accounts that are identified as Reportable Accounts from 1 July 2014 onwards, the Reporting Institution must ask for a self certification including a US TIN from account holders identified as resident in the US.

Where for a New Individual Account the account holder fails to provide a US TIN, the account is to be treated as reportable.

There is no requirement for a Financial Institution to verify that any US TIN provided is correct. A Financial Institution will not be held accountable where information supplied by an individual proves to be inaccurate provided that the Financial Institution had no reason to doubt that the veracity of the information provided.

A Financial Institution is not restricted by the manner that it records a TIN, for example, it is not necessary to retain a withholding certificate as the means of recording the TIN.