Instructions For Form W-8ben(E) - Certificate Of Entities Status Of Beneficial Owner For United States Tax Withholding And Reporting (Entities) Page 9

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requirements of an applicable IGA or the regulations
arrow pointing to line 9a is a properly provided GIIN for
under chapter 4 (a related entity), you must check "Branch
this purpose.
treated as nonparticipating FFI."
Line 10. This line may be used by you or by the
Line 12. Enter the address of the branch or disregarded
withholding agent or FFI to include any referencing
entity.
information that is useful to the withholding agent to
Line 13. If you are a reporting Model 1 FFI, reporting
document the beneficial owner. For example, withholding
Model 2 FFI, or participating FFI, you must enter the GIIN
agents who are required to associate the Form
on line 13 of your branch that receives the payment. If you
W-8BEN-E with a particular Form W-8IMY may want to
are a disregarded entity that completed Part I, line 3 of this
use line 10 for a referencing number or code that will
form and are receiving payments associated with this
make the association clear. You may also want to use
form, enter your GIIN. Do not enter your GIIN on line 9. If
line 10 to include the number of the account for which you
you are a U.S. branch, enter a GIIN applicable to any
are providing the form. If you are a single owner of a
other branch of the FFI (including in its residence country).
disregarded entity you may use line 10 to inform the
withholding agent that the account to which a payment is
If you are in the process of registering your branch
made or credited is held in the name of the disregarded
with the IRS but have not received a GIIN, you
TIP
entity (unless the name of the disregarded entity is
may complete this line by writing “applied for.”
required to be provided on line 3).
However, the person requesting this form from you must
receive and verify your GIIN within 90 days.
You may also use line 10 to identify income from a
notional principal contract that is not effectively connected
Part III – Claim of Tax Treaty Benefits
with the conduct of a trade or business in the United
States.
Line 14a. If you are claiming a reduced rate of, or
Part II – Disregarded Entity
exemption from, withholding under an income tax treaty
you must enter the country where you are a resident for
or Branch Receiving Payment
income tax treaty purposes and check the box to certify
Complete Part II for a disregarded entity that has its own
that you are a resident of that country.
GIIN and is receiving a withholdable payment, or for a
Line 14b. If you are claiming a reduced rate of, or
branch (including a branch that is a disregarded entity that
exemption from, withholding under an income tax treaty
does not have a GIIN) operating in a jurisdiction other than
you must check the box to certify that you:
the country of residence identified in line 2. For example,
Derive the item of income for which the treaty benefit is
assume ABC Co., which is a participating FFI resident in
claimed, and
Country A, operates through a branch in Country B (which
Meet the limitation on benefits provision contained in
is a Model 1 IGA jurisdiction) and the branch is treated as
the treaty, if any.
a reporting Model 1 FFI under the terms of the Country B
An item of income may be derived by either the entity
Model 1 IGA. ABC Co. should not enter its GIIN on line 9,
receiving the item of income or by the interest holders in
and the Country B branch should complete this Part II by
the entity or, in certain circumstances, both. An item of
identifying itself as a reporting Model 1 IGA FFI and
income paid to an entity is considered to be derived by the
providing its GIIN on line 13. If the Country B branch
entity only if the entity is not fiscally transparent under the
receiving the payment is a disregarded entity you may be
laws of the entity’s jurisdiction with respect to the item of
required to provide its legal name on line 3.
income. An item of income paid to an entity shall be
If the disregarded entity receiving a withholdable
considered to be derived by the interest holder in the
payment has its own GIIN, Part II should be
entity only if:
TIP
completed regardless of whether it is in the same
The interest holder is not fiscally transparent in its
country as the single owner identified in Part I.
jurisdiction with respect to the item of income, and
The entity is considered to be fiscally transparent under
If you have multiple branches/disregarded entities
the laws of the interest holder’s jurisdiction with respect to
receiving payments from the same withholding agent and
the item of income. An item of income paid directly to a
the information in Part I is the same for each branch/
type of entity specifically identified in a treaty as a resident
disregarded entity that will receive payments, a
of a treaty jurisdiction is treated as derived by a resident of
withholding agent may accept a single Form W-8BEN-E
that treaty jurisdiction.
from you with a schedule attached that includes all of the
Limitation on benefits treaty provisions. If you are a
Part II information for each branch/disregarded entity
resident of a foreign country that has entered into an
rather than separate Forms W-8BEN-E to identify each
income tax treaty with the United States that contains a
branch/disregarded entity receiving payments associated
limitation on benefits (LOB) article, you must complete
with the form and an allocation of the payment to each
one of the checkboxes in line 14b. You may only check a
branch/disregarded entity.
box if the limitation on benefits article in that treaty
Line 11. Check the one box that applies. If no box
includes a provision that corresponds to the checkbox on
applies to the disregarded entity, you do not need to
which you are relying to claim treaty benefits. A particular
complete this part. If you check reporting Model 1 FFI,
treaty might not include every type of test for which a
reporting Model 2 FFI, or participating FFI, you must
checkbox is provided. For example, “Company that meets
complete line 13 (see below). If your branch is a branch of
the derivative benefits test” is generally not available to a
a reporting IGA FFI that cannot comply with the
-9-
Instructions for Form W-8BEN-E (Rev. 7-2017)

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