Finland: Updated FATCA reporting requirements

Updated guidance regarding U.S. taxpayer identification number (TIN) reporting requirements for FATCA purposes

Updated guidance regarding U.S. taxpayer identification number (TIN) reporting requirement

Article Posted date 10 February 2023

The Finnish tax administration on 31 January 2023 issued updated guidance regarding U.S. taxpayer identification number (TIN) reporting requirements for FATCA purposes.

The updated guidance follows publication by the Internal Revenue Service (IRS) of Notice 2023-11 on 30 December 2022 (read TaxNewsFlash) providing relief to foreign financial institutions required to report missing U.S. TINs.

In accordance with the notice, for data reported for calendar years 2022, 2023, and 2024, a financial institution will not be considered significantly non-compliant for a missing U.S. TIN for a pre-existing account if the following conditions are satisfied:

  •  Financial institutions report the date of birth of each individual account holder and controlling person whose U.S. TIN cannot be reported
  • Beginning calendar year 2023, financial institutions annually request any missing U.S. TINs from account holders
  • Beginning calendar year 2023, financial institutions annually examine the archive material that it maintains electronically for any missing U.S. TINs
  • Financial institutions report an appropriate TIN code for each case in the TIN element

When requesting missing U.S. TINs, financial institutions must use the proper method of communication that is likely to reach each account holder. Financial institutions must provide the account holder:

Additionally, financial institutions must document and retain the policies and procedures applied for the fulfillment of the conditions described above, as well as documentation proving the adherence to the policies and procedures, until the end of calendar year 2028.

The tax administration notes that the previously released exception for reporting the U.S. TIN (national option) related to pre-existing personal accounts remains valid for Finland. As a reminder, in June 2021, the tax administration issued guidance on the exception to mandatory U.S. TIN collection, which includes cases in which the national option provided for in point A of section II of Annex I of the FATCA agreement may be applied if the following conditions are met:

  • Personal account is opened before 1 July 2014
  • Account balance did not exceed U.S. $50,000 on 30 June 2014, nor at the end of any subsequent calendar year
  • No new accounts were opened for the account holder since 30 June 2014.

Read a February 2023 report [PDF 208 KB] prepared by the KPMG member firm in Finland

 

 

Print friendly version

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.