Liechtenstein: Updated FATCA technical guidance for missing TIN

Liechtenstein: Updated FATCA technical guidance

The tax authority of Liechtenstein issued guidance (Newsletter 02/2021) relating to the procedures that must be followed in the event of a missing U.S. tax identification number (TIN) under the FATCA regime.

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According to the guidance:

  • All FATCA reports must be submitted to the tax administration by 30 June 2021 for the 2020 reporting year.
  • The reports must contain the U.S. TIN of the account holder or controlling person.
  • If a reporting Liechtenstein financial institution fails to obtain a U.S. TIN under any situation, this may constitute significant non-compliance and can lead to proceedings against the reporting Liechtenstein financial institution.

To determine the reason for a missing U.S. TIN, the U.S. tax authority (IRS) will provide additional reporting values (“dummy TIN values”) that can be used in the TIN field of the “Account Holder” or “Substantial Owner” for the 2020 reporting period. The new dummy TIN value is available in the tax instructions for FATCA reporting.

  • If the U.S. TIN is missing, the value “AAAAAAAAA,” or a specific dummy TIN value based on the circumstances, must be used.
  • The use of a dummy TIN is on a voluntary basis, but the U.S. TIN field must not be empty.

Also, according to the IRS, the dummy TIN value for dormant accounts is initially available only for the 2020 reporting period. Once the data is transmitted, the IRS will carry out a corresponding evaluation and decide whether dummy TIN values for dormant accounts will be continued. The remaining dummy TIN values are designed for permanent use. The use of dummy TIN values will yield the same error as the substitute value “AAAAAAAAA” for the IRS.

Finally, due to the short-term notification from the IRS, the technical implementation of the new dummy TIN values is expected to be completed by 31 March 2021. As a result, reporting Liechtenstein financial institutions are requested to submit their reports to the tax administration after 31 March 2021.

Read a February 2021 report [PDF 73 KB] prepared by the KPMG member firm in Liechtenstein

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