UAE: Updated FATCA FAQs and U.S. TIN reporting requirements
Guidance in alignment with U.S. IRS Notice 2024-78
The UAE Ministry of Finance (MOF) in April 2025 released an updated version of its FATCA “frequently asked questions” (FAQs) and a new FATCA Circular.
These documents outline the latest FATCA reporting requirements in alignment with the U.S. tax authority (IRS) Notice 2024-78, which extends the temporary relief provided in Notice 2023-11 for UAE reporting financial institutions that are unable to obtain and report U.S. tax identification numbers (TINs) for specified U.S. pre-existing reportable accounts until calendar year (CY) 2027.
During this period, reporting financial institutions will not be considered significantly non-compliant with FATCA obligations under the United States-UAE Intergovernmental Agreement (IGA) for failing to report the required U.S. TIN for preexisting accounts, provided reporting financial institutions perform the following actions:
- Obtain and report the date of birth for each account holder and controlling person whose U.S. TIN is not reported
- Request (annually) missing U.S. TINs from account holders, beginning CY 2023
- Search (annually) electronic records for any missing U.S TINs, beginning CY 2023
- Report an accurate TIN code provided by the IRS for each account missing a required U.S. TIN
- Report any foreign taxpayer identification number (FTIN) or functional equivalent assigned by the respective country of residence for each U.S. specified person missing a U.S. TIN
- Report the city and country of residence for each specified U.S. person missing a required TIN
- Use the 'AddressFix' element in the XML file to report the city and country of residence for each U.S. specified person with a missing U.S TIN
Read an April 2025 report prepared by the KPMG member firm in the UAE