IEIM401240 | NRFI: FATCA Only: Excepted Inter-Affiliate Foreign Financial Institution

NRFI: FATCA Only: Excepted Inter-Affiliate Foreign Financial Institution

To mirror the categories in the U.S. regulations certain group companies (likely to be holding companies or treasury centres of international groups) will be regarded as Certified Deemed Compliant Financial Institutions.

This category applies to an entity that is a member of a Participating FFI group if-

a) The entity does not maintain financial accounts (other than accounts maintained for members of its expanded affiliated group);

b) The entity does not hold an account with or receive payments from any withholding agent other than a member of its expanded affiliated group;

c) The entity does not make withholdable payments to any person other than to members of its expanded affiliated group that are not limited FFIs or limited branches; and

The entity has not agreed to report under §1.1471-4(d)(1)(ii) or otherwise act as an agent for chapter 4 purposes on behalf of any Financial Institution, including a member of its expanded affiliated group.

Participating FFI group

A participating FFI group is

• an expanded affiliated group that includes one or more participating FFIs;

• an expanded affiliated group in which one or more members of the group is a Reporting Model 1 FFI and each member of the group that is an FFI is a Registered Deemed-Compliant FFI, Non-Reporting IGA FFI, limited FFI, or retirement fund described in §1.1471-6(f) [these are the Exempt Beneficial Owner categories of retirement fund].

Participating FFI

A Participating FFI is an FFI that has agreed to comply with the requirements of an FFI agreement, including an FFI described in a Model 2 IGA that has agreed to comply with the requirements of an FFI agreement. The term participating FFI also includes a QI branch of a U.S. Financial Institution, as long as the branch is not a Reporting Model 1 FFI.