Paragraph 2 REGISTRATION OF NETHERLANDS FINANCIAL INSTITUTIONS
2.1: The Competent Authorities note that, under Article 4(1)(c) and Annex II of the IGA, a Reporting Netherlands Financial Institution or Paragraph 1.1.2 Financial Institution would be treated as compliant with, and not subject to withholding under, section 1471 of the U.S. Internal Revenue Code if the Reporting Netherlands Financial Institution or Paragraph 1.1.2 Financial Institution (or, as applicable, its sponsor or trustee), among other requirements, complies with the applicable registration requirements on the FATCA registration website. The Competent Authorities also note the IRS intends to issue a unique Global Intermediary Identification Number (‘GIIN’) to each Reporting Netherlands Financial Institution and Paragraph 1.1.2 Financial Institution that successfully completes the FATCA registration requirements.2.2: The IRS intends to include on the ‘IRS FFI Iist’ (as defined in section 1.1471-1(b)(73) of the U.S. Treasury Regulations) the name and GIIN of each Netherlands Financial Institution issued a GIIN by the FATCA Registration System. Pursuant to Article 5(2)(b) of the IGA and Paragraph 4.3.2.2, however, a registered Netherlands Financial Institution would be removed from the IRS FFIIist if an issue of significant non-compliance is not resolved within a period of eighteen (18) months.2.3: The U.S. Competent Authority intends to provide the Netherlands Competent Authority annually with the information necessary to identify each registered Netherlands Financial Institution included on the IRS FFI list.
