On the 2nd of June 2014, the IRS has electronically posted its first Foreign Financial Institution (FFI) list.
The relevant list includes all institutions that have finalized and filed their registration prior to the 5th of May 2014. The IRS intends to update the list and publish updates on a monthly basis. At the beginning of each month, a complete new list will be published for all financial institutions and branches that have an assigned and approved Global Intermediary Identification Number (GIIN). All FFIs that have received their GIIN by the 24th of June, will be listed on the July FFI List.
Downloading the complete FFI list is possible for those users that plan to import the list into their systems. Access is available by search, view and downloads of partial information using the FFI List search, as well as by using the download tool directly from the IRS Webpage for the full list.
The FFI List can be accessed by clicking here: http://apps.irs.gov/app/fatcaFfiList/flu.jsf
For payors of US sourced income, verifying a GIIN against the IRS FFI List is not required for payments made prior to January 1, 2015, with respect to any payee that is a prima facie FFI.
It is advisable for all Cyprus FFIs to complete the registration process no later than December 22, 2014, as to ensure their inclusion on the IRS FFI list that will be issued on the 1st of January 2015 and avoid any erroneous FATCA withholding from US payors. The issuance of a GIIN will allow the Cyprus FFIs to demonstrate FATCA compliance to their international business counterparties.
KPMG Cyprus and its international network are in a position to assist and advise clients throughout all the steps of the FATCA registration process.