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.


Related content

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

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 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal