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Does a sponsored entity have a FATCA ID and a GIIN

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A sponsored entity does not have a FATCA ID but does have a GIIN (Global Intermediary Identification Number).

The retrieved information clarifies that sponsored entities and sponsored subsidiary branches do not have FATCA IDs. Instead, they have a sponsored entity ID and cannot log in to the FATCA registration system. Once approved, sponsored entities and sponsored subsidiary branches are assigned GIINs and will appear on the FFI List if their sponsoring entity is also in approved status.

Additionally, the information specifies that a sponsored entity is required to provide its own GIIN (rather than the GIIN of its Sponsoring Entity) to withholding agents. The GIIN is used by the sponsored entity to identify itself to withholding agents and tax administrations for FATCA reporting.

Therefore, a sponsored entity has a GIIN but does not have a FATCA ID.

Sources:
Publication 5188 (7/2020)
Instructions for Form 8957 (06/2018)
Publication 5118 (07/2021)
Notice 2015-66
T.D. 9610
Publication 5190 (2/2022)

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