FATCA Basics: GIINs

A Global Intermediary Identification Number (GIIN) is the identification number that the IRS assigns to certain foreign financial institutions (FFI), branch of a financial institution (FI), direct reporting non-financial foreign entity (NFFE), sponsoring entity, certain sponsored entities, and sponsored subsidiary branch once the entity’s FATCA registration has been approved. The GIIN serves the purpose of identifying the registered entity to withholding agents and tax administrators for FATCA reporting purposes. It is comprised of 19 characters including period separators. The first six characters are assigned by the FATCA portal and are also known as the FATCA ID. The 14^th and 15^th characters are abbreviations for the entity type:

• LE - a lead FI

• SL - a single FI

• ME - a member FI

• BR - an FI branch

• SP - a sponsoring entity

• SF - a sponsored entity that is a sponsored fund

• SD - a sponsored entity that is a sponsored direct reporting NFFE

• SS - a sponsored entity that is a sponsored subsidiary

• SB - a sponsored subsidiary’s branch

The 17^th through 19^th characters are the three number country code of the GIIN holder. The IRS provides a complete list of FATCA country codes on its site.

Which Entities Must Obtain a GIIN?

For those participating in FATCA, the FATCA regulations and the Intergovernmental Agreement (IGA) implementing regulations require certain FIs to obtain a GIIN. Other entities can also obtain a GIIN, but it is not required. The determination whether an entity requires a GIIN is reached after conducting a FATCA entity classification analysis.

FATCA Portal Registration

When an entity registers in the IRS FATCA portal, a GIIN is frequently issued the day following online registration. Once the GIIN is issued, the registered entity will be identified on the published IRS FFI List the next time the list is updated. The IRS FFI List is updated monthly to add or remove entities.

GIIN Validation

If the GIIN does not yet appear on the IRS FFI List, counterparties will often accept a screen shot of the entity’s GIIN registration home page for validation purposes. When the GIIN is first provided to a counterparty through an IRS Form W-8 or a bespoke self-certification, the GIIN should be validated. It is possible for the IRS to approve the registration, issue the GIIN and, on the same day, revert the registration to incomplete status. This results in there being no approved GIIN for the entity. Accordingly, if the counterparty initially relies on the home page screen shot for validating the GIIN, the counterparty should make a note to validate the GIIN against the next IRS FFI List.

It is also possible for the IRS to remove the GIIN from the IRS FFI List at any point in the future if an issue arises with the entity or the entity’s FATCA registration. It is a useful best practice for the entity to check its IRS FATCA account periodically (e.g., every 6 months or 12 months). This will serve the dual role of ensuring the GIIN is still valid and there are no missed messages on the Message Board.

The counterparty should also establish a timeline in its policies and procedures for ongoing GIIN validation. If a client’s GIIN is removed from the IRS FFI List, the counterparty may have an obligation to undertake FATCA withholding depending on the counterparty’s jurisdiction. The IRS provides useful information regarding the timing of this withholding in its FAQs General Compliance Q25.

New Type of GIIN in 2027

The IRS system “Filing Information Returns Electronically” (FIRE) is being replaced by “Information Returns Intake System” (IRIS) in 2027. A new type of GIIN will be used to solve the issue faced by certain foreign filers who may be unable to obtain a Social Security Number (SSN) or Individual Tax Identification Number (ITIN) for their authorized users. The lack of an SSN or ITIN would result in the authorized users being unable to complete the authentication process which is required to apply for or maintain a Transmitter Control Code (TCC). Additional information about the Foreign Filer TCC registration process can be found on the IRS site.

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