Germany: Guidance on further extension of temporary relief for U.S. TIN codes

The U.S. tax authority (IRS) has extended the relief for U.S. TIN codes for an additional three years.

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December 4, 2024

The Federal Central Tax Office of Germany (BZSt) on November 19, 2024, released FATCA Newsletter 02/2024 containing the following updates:

  • Notice 2024-78, “Extension of Temporary Relief for Foreign Financial Institutions to Report US Taxpayer Identification Numbers,” issued by the IRS at the end of October 2024, extends temporary relief for foreign financial institutions regarding missing U.S. taxpayer identification numbers (TINs) for existing accounts through the 2025-2027 reporting periods. This extension builds on prior guidance from Notice 2023-11, addressing ongoing difficulties in procuring U.S. TINs for FATCA compliance. Read TaxNewsFlash
  • The transitional use of the code "AAAAAAAAA" for uncooperative account holders, as described in Notice 2017-46, has been replaced by "999999999" to indicate the absence of a U.S. TIN.
  • To prevent misunderstandings, clarifications on these updates will be incorporated into the FATCA Communication Manuals Parts 2 and 3 and published on the BZSt website.

Read a November 2024 report prepared by the KPMG member firm in Germany

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