This revenue procedure supplements the listing in Section 3 of Revenue Procedure 2014–64, 2014–53 I.R.B. 1022, as previously supplemented by Rev. Proc. 2016–56, 2016–52 I.R.B. 920, of the countries with respect to which the reporting requirement of §§ 1.6049–4(b)(5) and 1.6049–8(a) of the Income Tax Regulations applies, effective for interest paid on or after January 1, 2018.
This revenue procedure also supplements the listing in Section 4 of Revenue Procedure 2014–64, as previously supplemented by Rev. Proc. 2015–50, 2015–42 I.R.B. 583, Rev. Proc. 2016–18, 2016–17 I.R.B. 635, Rev. Proc. 2016–56, and Rev. Proc. 2017–31, 2017–16 I.R.B. 1104, of the countries with which the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) have determined that it is appropriate to have an automatic exchange relationship with respect to the information collected under §§ 1.6049–4(b)(5) and 1.6049–8(a).
Sections 1.6049–4(b)(5) and 1.6049–8(a), as revised by T.D. 9584, 2012–20 I.R.B. 900, require the reporting of certain deposit interest paid to nonresident alien individuals on or after January 1, 2013. Rev. Proc. 2012–24, 2012–20 I.R.B. 913, was published contemporaneously with the publication of T.D. 9584. Section 3 of that revenue procedure identified those countries with which the United States has in force an information exchange agreement, such that interest paid to residents of such countries must be reported by payors to the extent required under §§ 1.6049–4(b)(5) and 1.6049–8(a). Section 4 of that revenue procedure identified the countries with which the Treasury Department and the IRS had determined that it was appropriate to have an automatic exchange relationship with respect to the information collected under §§ 1.6049–4(b)(5) and 1.6049–8(a). Rev. Proc. 2012–24 was updated and superseded by Rev. Proc. 2014–64. Section 4 of Rev. Proc. 2014–64 contained an updated list of countries with which an automatic exchange relationship had been determined appropriate. Rev. Proc. 2014–64 was supplemented by Rev. Proc. 2015–50, Rev. Proc. 2016–18, Rev. Proc. 2016–56, and Rev. Proc. 2017–31. This revenue procedure further supplements Rev. Proc. 2014–64 by adding the Faroe Islands and Greenland to the list of countries in Section 3 of Rev. Proc. 2014–64 and by adding Croatia and Panama to the list of countries in Section 4 of Rev. Proc. 2014–64.
Section 3 of Rev. Proc. 2014–64, as previously supplemented by Rev. Proc. 2016–56, is further supplemented to read as follows:
The following are the countries with which the United States has in effect an income tax or other convention or bilateral agreement relating to the exchange of tax information within the meaning of section 6103(k)(4) pursuant to which the United States agrees to provide, as well as receive, information and under which the competent authority is the Secretary of the Treasury or his delegate:
Antigua & Barbuda
Aruba
Australia
Austria
Azerbaijan
Bangladesh
Barbados
Belgium
Bermuda
Brazil
British Virgin Islands
Bulgaria
Canada
Cayman Islands
China
Colombia
Costa Rica
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominica
Dominican Republic
Egypt
Estonia
Faroe Islands
Finland
France
Germany
Gibraltar
Greece
Greenland
Grenada
Guernsey
Guyana
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Jamaica
Japan
Jersey
Kazakhstan
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Marshall Islands
Mauritius
Mexico
Monaco
Morocco
Netherlands
Netherlands island territories: Bonaire, Saba, and St. Eustatius
New Zealand
Norway
Pakistan
Panama
Peru
Philippines
Poland
Portugal
Romania
Russian Federation
Saint Lucia
Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
St. Maarten (Dutch part)
Sweden
Switzerland
Thailand
Trinidad and Tobago
Tunisia
Turkey
Ukraine
United Kingdom
Venezuela
Section 4 of Rev. Proc. 2014–64, as supplemented by Rev. Proc. 2015–50, Rev. Proc. 2016–18, Rev. Proc. 2016–56, and Rev. Proc. 2017–31, is further supplemented to read as follows:
The following list identifies the countries with which the automatic exchange of the information collected under §§ 1.6049–4(b)(5) and 1.6049–8 has been determined by the Treasury Department and the IRS to be appropriate:
Australia
Azerbaijan
Belgium
Brazil
Canada
Colombia
Croatia
Czech Republic
Denmark
Estonia
Finland
France
Germany
Gibraltar
Guernsey
Hungary
Iceland
India
Ireland
Isle of Man
Israel
Italy
Jamaica
Jersey
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Mauritius
Mexico
Netherlands
New Zealand
Norway
Panama
Poland
Portugal
Saint Lucia
Slovak Republic
Slovenia
South Africa
Spain
Sweden
United Kingdom
Rev. Proc. 2014–64, as supplemented by Rev. Proc. 2015–50, Rev. Proc. 2016–18, Rev. Proc. 2016–56, and Rev. Proc. 2017–31, is further supplemented.
With respect to the additional countries listed in Section 3, this revenue procedure is effective for interest paid on or after January 1, 2018.
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