TREATIES AND OTHER INTERNATIONAL ACTS SERIES 15-122.2

________________________________________________________________________

TAXATION

Foreign Account Tax Compliance 

Agreement Between the 

UNITED STATES OF AMERICA

and LIECHTENSTEIN

Signed at Vaduz May 16, 2014 

with

Annexes
 NOTE BY THE DEPARTMENT OF STATE

 Pursuant to Public Law 89—497, approved July 8, 1966

(80 Stat. 271; 1 U.S.C. 113)—

“. . .the Treaties and Other International Acts Series issued

under the authority of the Secretary of State shall be competent

evidence . . . of the treaties, international agreements other than

treaties, and proclamations by the President of such treaties and

international agreements other than treaties, as the case may be, 

therein contained, in all the courts of law and equity and of maritime

jurisdiction, and in all the tribunals and public offices of the

United States, and of the several States, without any further proof

or authentication thereof.”
 LIECHTENSTEIN 

 

 Taxation: Foreign Account Tax Compliance 

 Agreement signed at Vaduz May 16, 2014;

 Entered into force January 22, 2015.

 With annexes.
Agreement between· the Government .of the United States .of America and the 

GOvernment of the Principality o( Liec4ten~tein to Improve International Tax 

Compliance.and to Implement FATCA 

Whereas, t}le Government of the United States of America and the Government of the 

Principality of Liechtenstein {eaCh, ·a "Party," and tog~tb~~ the "Pa:rties'~):bave a longstanding 

and close relationship with respect to mutual assistance. in tax matters and desire to oonclude 

an agreement to improve international tax compliance by further building on that 

relationship; 

\\'hereas, the ~ent between·the Government of.the.United S~es ofAmerica and the 

Gavemment aftbe Priricipality of Liechtenstein onTax Coq~tion.and the·Exchan.geof 

Information Relating to Taxes· (the "TIEA "), done at Vadui on December 8, 2008 authorizes 

the exchange of information for tax purposes; 

Whereas, a protocolarrtending the TIEA was signed .at Vaduz,on May 16, 2014 

(the "Protocol") and includes a provision expressly permitting the automatic exchange <;>f 

information for tax purposes; 

Whereas, the United States ofAmerica enacted provisions,9PIP111only l,mown .as the Foreign 

Account Tax Compliance Aet ("FATCA "),which introducea·reporting regime for financial 

institutions with re~pect:W.c~n a~qn~; 

Whereas, the Qa~~tpft}le Jlrin<;ipality.()fLiec~JS.'St,lP.p<lrtive:ofthe underlying 

policy goal ofFATCA to improve tax oomplianre; 

Wh~, fATPA.~~~eci A Jlllm .. :O.(,~u~~J\ldmg$a.t:U®lttetl$tem financial 

institutions may ll()tbe able to oottmlY cwith certain aspects ofF.AtOA duefto dmnestie legal 

impediments; 

;;,' 

Wheteas, the Govemm.ent.ofthe UniteilStates ofk'u«ica collects information r¢garding · · · • ; · ·• :ts ....,GJ.,..ta~-...h ·U Q · . ..:.;.aneial :..o~tufirina n...tA '"' · · · )ients offEiechtenstein ¢ertai!l.acp9~ ·~~~ .. ~ •. ··~""'~4L' .•..• , .• ~~·~··"'~· ~~"' ~ ..•......•.. · ... ·· 

and is oonuriiUed to exchanging .such information with• the. Gov~entof the Principality of 

Uechtenstein an~ pur$Uing equivalent levels of exchange; 

Whereas, the Parties ~e committed to working togetberu~:·fbe,l<mger term towards 

achieving common reporting ·and due diligence •starldatds for financial institutionS; 

Whereas, the. G()vex:mpepl Qf.t}le United. States of~~cacacknowledges then®d to 

coordinate the reporting. obligations under FATCA with other U.S. tax reporting obligations 

of Liechten~infinancial institutions to ~vpid d1,1plic:;atiye xeporting; 

Whereas, an intergovernmental approach to FATCAimplementation V/Ould address legal 

impediments and reduce burdens for Liechtenstein financial institutions; 
Whereas, the Parties desire to· conclude an agreement to impro\re intenia'fional taX compliance 

and proVide "tot tlie implementation ofFATCA based on domestic reporting arid reciprocal 

automatic exch4mge pUl'Stlant to the ~ as amended by the Protocol, and subject to the 

confidentiality and other protections provided for therein, including the provisions limiting 

the use of the information exchanged under the TIEA; 

Now .. therefore, the·Parties have agreed as follows: 

Amclet 

Deimitions 

1. Forpurposes of1hisagreement and any annexes thereto~\uAgteemetttj, the following 

terms sbaJJ hav.e. the meanings set forth below: 

a) 

b) 

c) 

d) 

e) 

f) 

The term "United States" means the United States of America, including the 

States thereof, but does not include the U.S. Territories. Any reference to a 

''State" ofthe United States includes the District of COIW:nbia. 

The term "U.S. Territory" means American Samoa, the Ctiimnonwealth of 

the Northern Mariana Islands, Guam, the Commonwealth of Puerto Rico, or 

the U;S. Virgin Islands. 

The term "IRS" means the U.S. Internal Revenue SerVice. 

".rhb't'el'$ ~lilieeattemteiu~ means the Principality ofUeCffit~tein. 

The term JIOP•J,:tnerJu,ris4ietion"' means ajurisdicmontbat has in effect an 

-agr~MrWitbthetJnited!States·to taciiitate'thennplementfltion·ofFATCA. 

1be·JRS·shall pub1isb 'a list Rrermrying all Partner Jl:mMictibns. 

The term "Compe~nt Authority" means: 

.(1). 

(2) 

· m\tbe'ea$e nf1he1Jnited StateS" ilie Secteuuy~ofitliij '1Teasury·or his 

del~·ud 

in the ease of Liechtenstein, the Government or its authorized 

~tative. 

g) The term "F'inandal Institution~ means a Custodial Institution, a Depository 

lnstitution,:an InveWnenfEtttitY~ or a Specified InsumnceCompany. 

h) The term "Custodial ~tUtion" means any Entity that holds, as a 

substantial portion ofits business, financial assets for the acoount of others. 

An entity holds firumcial ~ets for the account ofothers as a substantial 

portion of its business ifthe entity's gross income attributable to the holding of 

financial assets and related financial service..<; equals or exceeds 20 percent of 

the entity's gross income during the shorter of: (i) the three-year period that 

ends on December 31 (or the final day of a non-calendar year accounting 

period) prior to the year in which the detennination is being made; or (ii) the 

period during which the entity has been in existence. 
i) The term "Depositoey Institution" means any Entity that accepts deposits in 

the orditlary course. 9f~ '®nking or siniilar bl.lsiness. 

j) The~ "J1,1v~tjne1,1~ ."nfity" means. any Entity ~tP9J1ducts as a business 

(or is managed by an entity that conducts as a business) one or more of the 

following activities or operations for or on behalf of a customer: 

k) 

l) 

m) 

n) 

o) 

p) 

( 1) . trading in money market instruments (cheques, bills. certificates of 

d~~ d¢vatiyes, et~.); fo~ign ex~g~.; ~clumge, interest rate 

and index: inStruments; ·:transferable securities; ot commodity futures 

trading; . 

(2) individual and collective portfolio ma.nag;ement; or 

(3). otherwise investing, administering, or man~ng foods or money on 

})ebalf ofother pei:sons. 

'.flU$ ~~h l(j) s~L~·in~ed in a l)lanner ,consistent with similar 

Ianglligeset forth in thedefmitionof"'financial institution" in the Financial 

Action Task Force Recommendations. · ·. 

The term ~spectraedln-surance.Compa~y~ meaps,~y ~tity,.that is an 

insur'anCe company (or the b~lding comp8llY of an insurance company) that 

· ·issues.~¢ is obli~~~,~~ ~ents withre~ to, a Cash Value 

~~.Qr~,~tY;CoJ1~ . 

'The temt~Llldttensteib riOtUteial~tptiou».~;({)any ~inancial 

~tionresicblt in ot~~i~ under the laws, ofLiec~~ but 

:ClfcindiJli'AAf·blandl.o.tsuoh}!-aialJnstitution:that iSJocatedoutside Li~~in · . ··. · '' /. ·'' ~t;.;.;.:L:~~, t:'it •·. · 'a1~t-~1JJttoo not~ent in or . , . ·.• . ~~t<' ~.,~,.~':9; ~A~~L .~.Ll''il< •.• ~,. .. .·. · · 

~~~er. e . ~;'P{J4~J.f~uQ,b:~~Q,b is looated in 

~~-· 

. ·Th~;t~·'fPJ~liaer . .J~iis4l~o.}. &andallns~tion"' means (i) any 

Ei~ij Wtllt.\QQne$-blishM~.a~JUtiSdi~Qll, but. excluding any 

brancili nfsuch ':Financial Instiurtion'·thatis loCated outside the Partner 

Jurisdiction, and (ii) any braflch .ola F!ll8Ilcia1 Institution not established in the 

P~ Jurisdiction, if such .bf8ll,Ch is located in the Partner Jurisdiction. 

The tenn "R~P,pdingFj~~~.Jnstitnti~n" means~ J:{eporting Liechtenstein 

.Finan~iallnstitution or a ReportingU:S~ Financial Institution, as the context 

requires; 

The tenn "Reporting Liechtenstein Financial Institution" means any 

Liechtenstein Financial Institution that is not a Non-Reporting Liechtenstein 

Financial Institution. 

The tenn "Reporting U.S. Financial Institution" means (i) any Financial 
Institution that is resident in the United States, but excluding any branch of 

such Financial Institution that is located outside the United States, and (ii) any 

branch of a Financial Institution not resident in the United States, if such 

branch is located in the United States, provided that the Financial Institution or 

branch has control, receipt, or custody of income with respect to which 

informl:ltionis required to be·exchanged under subparagraph (2)(b) of Article 2 

of this Agreement. . 

The term "Non-Reporting Liechtenstein Finandallnstitution" means any 

Liechtenstein$itl8ricia1Institution, or other Entity resident in Liechtenstein, 

that is described in AnneJdl as a Non-ReportingLiechtenstein Financial 

Institution oitllai otherWise qualifies as a deetn:ecl-compliant FFI or an exempt 

beneficial owner under relevant U.S. Treasury Regulations. 

r) The term "Nonparticipating Financial Institution" means a nonparticipating 

FFI, as that term is defined in relevant U.S. Treasury Regulations, but does not 

include a Liechtenstein Financial Institution or other Partner Jurisdiction 

Financial Institution other than a Financial Institution treated as a 

Nonparticipating Financial Institution pursuant to subparagraph 2(b)of Article 

5 of1his Agreement·orthe corresponding provision in an agreement between 

the United States and tlPartner Jurisdiction. 

s) The term "Financial Account" means an account maintained by a Financial 

Institution, an:d includes: 

(1) 

(2) 

(3) 

1n the ca$C ofan Entity that is a Financial Institution solely because it 

is an Investment'Entity, any equityordebt Interest (other than interests 

that are regularly traded on an established securities market) in the 

Fmimtial r~tlrtirur · .. ~ + • ' 

iii the t&Se-'c)f'aFipanciat.'Irlstitution not described' in subparagraph 

1 ts)(i)'ofthls :Alticl~ :any 'equity or:debi'lntereSt in the Financial 

wtltittioir(oiher tluttfi~tS that are regularly 'traded on an 

eStabliShed securities:market), xf(i) the value of the debt or equity 

~st i~ d~~ined. directly or indirectly, primarily by reference to 

as8ets'f.hat gtv~ nset.OU;S. Souree·Withholtlable Payments, and (ii) the 

cl~ otinterests wa$:established with aopurpose of avoiding reporting 

in''tcordance 'With this Agreement; rutd 

any Cash value Insurance Contract and any Annuity Contract issued or 

maintained by a Financial Institution, other than a noninvestmentliDked, nontransferable immecliate ~ife annuity that is issued to an 

individual and monetizes a 'P'ellsi6n or disability benefit provided under 

rut account that is excluded from the definition of Financial Account in 

Annex II. 

Notwithstanding the foregoing, the term "Financial Account" does not include 

any account, product, or arrangement that is excluded from the definition of 

Financial Account in Annex II. For purposes of this Agreement, interests are 

''regularly traded" ifthere is a meaningful volume of trading with respect to 
t) 

u) 

v) 

w) 

x) 

the:interests on an ongoing basis, and an "established securities market" means 

an e~change tltat is officially t:ecognized m1d supervised by a governmental 

authority in which the market is located and that has a meaningful annual 

va}ue of shares traded on the. exchange. For purposes of this subparagraph 

I(~)~ ~ i~rest in a Financial Insti.tution is J}Ot "feiDllady traded" and shall not 

be treated as a.'FinancialAccount ifthe.holder of the interest (other than a 

Financial Institution ~cPtm as, an.mterlllediary) is first registered on the books 

of such Financial InStitution. the preceding sentence will not apply to 

interests first registered on the books of such Financial Institution prior to July 

1, 2014~3.1ld with.~ttoihter~registered on the books of such Financial 

Institution on or after July 1,. 2014, a Financial Institution is not required to 

applytQ.eprececling.sentence prlQr.to January 1. 2016. 

The t~ "Dep~sitoey Account" includes. any commercial, checking, savings, 

time, or thrift account, or an account 'that is evidenced by a certificate of 

deposit, thrift certificate, investment certificate, certificate of indebtedness, or 

other similar instrument. maintained by a Financial Institution in the ordinary 

course of a banking .or similar business. A Depository Account also includes 

an amount held by an insurance company pursuant to a guaranteed investment 

contract.or similar agreement to pay or credit interest thereon. 

Thete~ ~ustodi,lAceount" means an account (other than an Insurance 

Con~ .. ~r ~~ Contmctif9~.the·.benefitof another person that holds any 

~~ial~~t•or p>~~beld.(or.inv~ent (including •. but not limited 

to,·asbare.orstoGk in a;corpo.ration,a not~~.bond, debenture, or other evidence 

of ind~, a curiency or cOtnmodity transaction, a credit default swap, a 

.~~upon a ~at. ii'l<fe.X a~otional principal contract, an 

I~ce Contract or Annuitf.G9.ptnlri4,~d any option or other derivative. 

instrument)~ 

The, .··.. . ~'li'ft • ]n ' t"' m. .• ..... tlle<case of a n<S..tne,WU that is a . . teq;q. .. ~~w ~ .~. ,~t·lll . ., , .. , . ¥-""'· " .P. . . Financial .institution, either'a capital or profits interest in the partnership. In 

. the~~~:~.~tJll:,'-.~~~~.J~Wfi~anEquit¥ Int~ is 

~$red to'~·beld .. by any.,p~:treauklas.a'Settlor or.beneficiary of all or 

.a pq1tlGJ:l;t)fth~ tnJst OJ.~~~.~ pemon ~~ising pJ~te effective 

~:OV.·1hettust~ ASpeeitiedU~ .• ;~nshaij be treated~ being a 

bet1efici.a.i.y .of a foreign tniSt··if suchSpecifi~ U.S. Person has the right to 

receive diJ'ecAy or indirectly (fore$a;mplc:, thrqugh a nominee) a mandatory 

distribution or may receive, direetly or indirectly~ a discretionary distribution 

from :the trust. 

The tenn "Insurance Contract".means a contract (other than an Annuity 

Contract) under which the issuer agrees to pay an amount upon the occurrence 

of a specified contingency involving mortality, morbidity, accident, liability, or 

property risk. 

The term "Annuity Contract" means a contract under which the issuer agrees 

to make payments for a period of time detemtined in whole or in part by 

reference to the life expectancy of one or more individuals. The term also 

includes a contract that is considered to be an Annuity Contract in accordance 
with the law, regulation, or practice of the jurisdiction in which the contract 

was issued, and under which the issuer agrees to make payments for a term of 

years. 

y) The term "Cash Value ln$urance Contract" means an Insurance Contract 

(Other than an indemnity reinsurance contract between two insurance 

companie8) that has a Cash Value gteater than $50,000. 

z) The·term "Cash Value" means the greater of(i) the amount that the 

policyholder is e11titled to receive upon surrender or termination of the 

contract (determined without reduction for any surrender charge or policy 

loan)~ and (ii) the.amount the policyholder can borrow under or with regard to 

the contract. Notwithstanding the foregoing, the term "Cash Value" does not 

include an amount payable WideraiiinstiranceContr.ict as: 

aa) 

bb) 

cc) 

( 1) a personal injury or sickness benefit or other benefit providing 

indemnification of an economic loSs incurred upon the occurrence of 

the event inSured against; 

(2) a refund to the policyholder of a previoo5ly paid premium under an 

Insurance Contract (other than under a life insurance contract) due to 

policy caneellation or termination, decrease in risk exposure during the 

effective period ofthe Insurance Contract, or arising from a 

tedeterinination ofthe pretnium due'to rottection of posting or other 

similar eirot; o.t' 

(3) a policyhdtder·dividertd based upori: the underwdting experience ofthe 

contract or group involved. 

The term "ReportableAceount" means a U.S. Reportable Account or a 

Liechtenstein Re'portabl~'Ax~oo'unt; as.the conteXt reqUires. 

The term "Liecli~elistt;in Reportable ~cc:~-Qnt" means ~a Financial Account 

maintained by·a ReportingU.S.·Financial Institution if:· (i)·in the case of a 

Depository Account, the account is helctby anindiVidual resident in 

Liech~md more than $10 orinterest is paid to' such accotint in any 

given calendar~; or:(H) in the case af.a Financial Account other than a 

Depository AccOunt; ure A~tint Holder is a resident of Liechtenstein, 

including an Entity th-at-certifies that it is resident· in Liechtenstein for tax 

purposes. with respect to which U.S. source income that is subject to reporting 

under chapter 3 of subtitle A or chapter 61 of subtitle F of the U.S. Internal 

Revenue Code is paid or·eredited. 

The term "U.S. Reportable Account" means a Financial Account maintained 

by a Reporting Liechtenstein Financial Institution and held by one or more 

Specified U.S. Persons or by a Non-U.S. Entity with one or more Controlling 

Persons that is a Specified U.S. Person. Notwithstanding the foregoing, an 

account shall not be treated as a U.S. Reportable Account if such account is 

not identified as a U.S. Reportable Account after application of the due 

diligence procedures in Annex I. 
dd) Th~tenn « ~~~UJ'ltJlqlder"lllean~ ~e~Qn, li~ or .iqe~fied as the 

holdetof.a Fjn~cial ~co~ by tJieFmancial~tution that:tnaintains the 

~unt. A:;pelSpD,;:.Qther:than.aFiiUlDcial.~~hoJdinga.Financial 

Accoqnt fox: tbe benefit or account of anotJi~~n;as.agent,. c~stodian, 

nominee.. .sigmttory. investment advisor, or intenne.diary, is not treated as 

bol~gtb¢~tfQJ; ~Qf:thiS.~~~t,.~dSl:lch other person is 

treated as holding the oooount. For.putposes ofthe immediately preceding 

s(!Jltence.;the te~ "F'UlaAciaLlnstitutjqn~' <l~:not.include a Financial 

InStitution qrganized or .ineotpotated in aU .S.Territory. In the case of a Cash 

.Value.lnsurance. Co.n:tqmtm:ap:Atmuit.y"CooD;act,·~Account Holder is any 

~.~riti.tl~:tp~.;tJiq.~,:\{f;d~.9t.~ge ~:benefici~ of the 

contract.: .lft:l~,perso~!Dalt~ccess the.Cash Yalue ~r ~ge .the beneficiary, the 

A~ot1Dt;H9~~i~ ~i·~n:WJme9~·~;~wn~inth~ CQ!l~t and any 

person with,e ·veste9-~titlem~t·to ~xment under the..te1'111S. of the contract. 

Upon tJie maturity.of:aCash Value ln.surar;tce~Contract ~r .~Annuity Contract, 

each ~J,t entitled to.ireceiv:e ap.~yment under the.contract is treated as an 

Account Holder. 

ee) The tenn.~U.S.}:l!ets~JJr'.melltlS'a ;lJ,;S. citizen; ()t·r~iden.tindi'lidual, a 

pa$~hjp OJ't~~prpn;i~,~ th~JJ)l!tq,i S~~ 91' 11Dder the laws of 

the lJJlited S,tates:()f -~ .~tetl!lereof,.~ t:rtJst.if(i)'~ C9urt within the United 

.. S~.:wolll4~·a~tJ:·m\d~,app~le:J,a.wf9~.Q~ers or . J~ · ... ..~~en;ts. · ···· · ·' · su~ti"'11~~aiC. · · l'e~~ ... administration of the ..•. ~s .... ~ ...... ,,.,i,..,.~· ........ ~. Q~"ffl'!'& .... . 

~,~~;~*~~'Q~Sf.~J~"P~~il~'tfrt<l coptrol all 

su~ti~deci$*~~~ qn~~~t~:<t~~is a citizen or 

resident of the United States. This.subpatagraph l(ee) thall be interpreted in 

~~~ewitk~ U~JAt~m•.~uC,r~;· 

lf) 1peJ.,QJ;l'~·~u.&/J;t,.Ji~IQ.~).(ti{J~.;;:e~~e,;tban: .(i) a. 

coiporati~:Ute··~~.~Qf.~ChiJ;~y,,tfaded ~;~~~~ esQiblisbed 

securities matkets;:.{ii) en,yc~oit1hat.is amentber•Aflhe.same expanded .. ;A:;t:-.....1 ' .• ~;,;..~ .,•· ~;1:j~Uh1lr.)} .... ~ ........ Jl·C! latemal l{e ~~~~~:.~~~.~~~. ~~~-..A.t~~~~~·· ~··""'' •. , •. :venue r:t~.f• .·· .. ·. ;...~-i;J 'riA/1~ .~. ~(J;\. t•·nm n..;.·!+....J.Sta,tes 't ~•a··~t('W":'!"'!:<t~..,.~~A ·.····· ,,a;~~1t~:~r .~~~. .o any. 

:whWlY:~~gy~r~~tb~~.fj.Y~:AA¥~~ftheUnited 

~~.;u;.s~:~~~J:~~·~V:i~~n,.qf';~.ofthe foregoing, or 

illl:f.wboUy owned:~y~ot~~it¥·of~ .• Qnepr.mgreofthe n .·.· ..•. ·.·· ; ·(y), ·. . j~ . -tl.f. froiD ... ··on under section50l(a) of Ql'eg<>.JPg. · 7·~Y ~ ~Y.M"OJl eJ'~-..~ .·. .~ . · ..... · . . . 

the u,S .. nlnte~ Rtwc;qu~Cqde or~)ndlviduaJ,retiremerrt:plan as defined in 

section 77Ql(a){37) of the U.S.Intel'l;lal~¢nqe C.Qtie;..(:vi) ~y bank as 

defined in section 581 ofthe lJ.S. Intema.I Revenue Code; (vli) any real estate 

· i,ny~nt ~tas:ld~~cms~Qn.,·~5P of~e U.S. lilt~ ReVenue Code; 

· (viii)~y·re~la~inv:e@n¢nt,eompaay.a:sdefinedi:n·seotion851.ofthe U.S. 

Internal &evenue.Code or,~y:entity,regi~edwitJi the U.S. S~urities and 

Exchange Commission under tJie Investment Company Act of 1940 (151J.S.C. 

80a-64); (ix) any common.trust fund as defined in section 584(a) ofthe U.S. 

lntemal Revenue Code; (x) any trust that is exempt from tax under section 

664(c) of the U.S. Internal Revenue Code or that is described in section 

4947(a)(l) of the U.S. Internal Revenue Code; (xi) a dealer in securities, 

commodities, or derivative financial instruments (including notional principal 
contracts, futures, forwards, and options) that is registered as such under the 

laws of the United States or any State; (xii) a broker as defined in section 

6045(c) of the U.S; Internal Revenue Code; or (xiii) any tax-exempt trust 

under a plan,that is described in section 403(b) or section 457(g) of the US 

Internal Revenue Code. 

gg) The term "Entity" means a legal person or a legal arrangement such as a trust. 

hh) The term "Non-U.S. Entity" means·an Entity that is not a U.S. Person. 

ii) The term "U.S. Source.'Witbboldable Payment" means any payment of 

inteteSt{including any'Original issue discount), dividends. rents, salaries, 

wages, premiums; annuities, compensations, remunerations, emoluments, and 

other fixed or determinable annual or periodical gains, profits., and income, if 

such payment is from sources within the United States. Notwithstanding the 

foregoing, a U.S. So'Ul'Ce WithholdablePayment does not include any payment 

that is not treated·es awithhotdable payment in rele'Vant U.S. Treasury 

Regulations. 

jj) An Entity is a "Related Entity" of another Entity if either Entity controls the 

other Entity, or'the two Entities are under common control. For this purpose 

control includes ditect or incliteGt ownership of more 'than 50 percent of the 

vote orNalue in an Entity. Notwithstanding the foregoing, Liechtenstein may 

treat an Bntity as not a Related Entity of another Enti'}' if1he two Entities· are 

not: m~ ·of the same ~de(! affiliated . group as defined in section 

1471 (e){2) ofthe: U:S. Internal Revenue Ct>de. 

kk) The term "U.S. TIN" means a U:S; federal taxpayetidentifying number. 

ll) The= term ~Lieclitenstein TJNn'mearura Liechtenstein taxpayer identifying 

number; 

mm) The tefJ:t'(.~Controlling Pe~n~" means the natural persons Who exeroise 

control over 'ali Entity; In the case ofaWs4SUch term means the settlor, the 

ttt.tStees. :the protector (ifiattY),'the: beneficiaries• or class. ·of beileficiaries, and 

any-other natuntJJpei'SGn ex~itlg. Ultimate effective control 'Over the trust, 

and 1n: the: caSe: of aJegaJ ar18ngemeilt'Otberthan a trus4 such term means 

persons in equivalent ot gbnilar p&sitions: Th.e'term ••eonttotliilg Persons" 

shalr be interpreted in a manner consistent with the Firiancial Action Task 

Force Recommendations. 

2. Any term not otherwise defined in this Agreement shall, unless the context otherwise 

requires or the Competent Authorities agree to a common meaning (as permitted by domestic 

law), have the meaning that it has at that time under the law ofthe Party applying this 

Agreement, any meaning under the applicable tax laws of that Party prevailing over a 

meaning given to the term under other laws of that Party. 
ArtieJe2. 

Obligations to Obtain and Exchange Information with Respecno Reportable Accounts 

1. ~.Ubj~t ~o theprovjsJons ofMjcle.~ of:~:~ Ag,;e~gJent, ~h Party shall obtain the 

informationspecified:in,~h 2 ofthisArti~Ie:With•respecttO.:allReportableAccounts 

an<l sl¥!1l·atlti~ly exc,l:tAAgf! ~s ~~()P wi~ ~e qih~ Party on. em automatic basis 

pursuant to the provisionS of Article SA ofth~tfiB:~ ·as ~en<led by the Protocol. 

2. The information to be ootaihed and. ex~t!d is: 

a) In the case of LiechteD$tein with r~pectto each u:S. Reportable Account of 

each Reporti~ Uecbtenstein FinaneiaUn8titution: 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

the name, address, and U.S. TINofe~h Specified U.S. Person that is 

an Accomtt Holderofsuch.~:untand, in the case ofa Non-U.S. 

Entity that, ~ appli~tjg~ (}f the dqe ifillgence procedures set forth in 

Annex I, is identifie<l as havitm one or more Controlling Persons that is 

a $pecified U.S~ Pe,~p, thr~.n~ addr~s, ~dU.S. TIN (if any) of 

such entity and each such Specified U.S. Person; 

the accomtt nW11ber. (~rf4n~tio1W equiValent ip the absence of an 

accomtt numbei-); · · 

fhe,narne and :iden~g number ~f.the Reporting Liechtenstein 

Financial Institutio:ti ·. · 

the ~ount balance orvalue(mcl~:in ~·~case of a Cash Value 

Insurance Co.nttact :~Atm.UitfCO~tbe·~·value~or s~nder 

-yal~e)·.aaclthe t;nd of,th.e,ml~ caJ~ar Y:t!ar ot other appropriate re · · ~ • . .·· • ·· . · t .· : ' ' · · · ·· .•clos«i .durin such . ~·~~lJ-,i,t~.~-~· ., ..... , g. year. 

· ediatel .. befote.clesmc· . umt1 .Y '·. •t: 

in the case of a:ny.~Account: 

(A) the·t~tal ~.~Q~.pftnt- th~~ktgross amount of 

dividen~~~~~:~~llnt;Of\~income .. 

genera~~ Witti~t~ #ie~ h~ld m thc.account, m each 

case paid Pf.~<~ditet;t() tlte·~~unt{orwith respect to the 

account). .during:the calendar· .ycar.or .other. appropriate reporting 

(B) 

period;: and · · 

the tQtal,.gJ:o~~.prqce.eds from the saJe .or redqnption ()fproperty 

paid or.eredited to .. the ~COUnt.d~the .calendar year or other 

appropriate reporting period with respect to which the 

Reporting Liechtenstein Financial Institution acted as a 

custodian, .broker, nominee. or otherwise as an agent for the 

Account Holder; 

in the case of any Depository Account, the total gross amount of 

interest paid or credited to the account during the calendar year or 
other appropriate reporting period; and 

(7) in the case of any account not described in subparagraph 2(a)(5) or 

2(8)(6) of this Article, the total gross amount paid or credited to the 

Account Holder with respect to fhe account during the calendar year or 

other appropriate reporting period with respect to which the Reporting 

Liechtenstein Financial Institution is the obligor or debtor, including 

the aggregate amount of any redemption payments made to the 

Account Holder during the calendar year or other appropriate reporting 

period. 

b) In the case of the United States. with respect to each Liechtenstein Reportable 

Account of each Reporting U.S. Financial Institution: 

( 1) the name, address, and Liechtenstein TIN of any person that is a 

resident ofLiechtenstein and is anAccount Holder of the account; 

(2) the account number (or the functional equivalent in the absence of an 

account number); 

(3) the name and identifying number of the Reporting U.S. Financial 

Institution; 

( 4) the gross amount ofinterest paid on. a; Depository Account; 

(5) the gross amount of U.S. source dividends paid or credited to the 

account; and 

(6) the :gross amount of other U.S. source income paid or credited to the 

account, to the extent subject to reporting under chapter 3 of subtitle A 

or chapter 61 of subtitle F of the U.S. Internal Revenue Code. 

Article3 

Time and Manner of Exchange of Information 

1. For purposes of the exchange obligation in Article 2 of this Agreement, the amount 

and characterization of payments made with 'respect to a U.S. Reportable Account may be 

determined in accordance with the principles of the tax laws ofLiechtenstein, and the amount 

and characterization of payments made vii.th respect to a Liechtenstein Reportable Account 

may be determined in accordance with principles ofU.S. federal income tax law. 

2. For purposes of the exchange obligation in Article 2 of this Agreement, the 

information exchanged shall identifY the currency in which each relevant amount is 

denominated. 

3. With respect to paragraph 2 of Article 2 of this Agreement, information is to be 

obtained and exchanged with respect to 2014 and all subsequent years, except that: 
a) In the case-of Liechtenstein: 

b) 

(1) the info~ation tQ be obtained,~ exchanged with respect to. 2014 is 

· ot1ly pte irifo~at;iop d~l;wA iti:suhpaqlfirap}ls 2(a)(l) throu.gh 

2(a)(4) .of Article 2 .ofthis~eet1lent;: 

{2) the.Jnformationto.be ~bfain~ and;ex~ wifh·.t:eS~cUo201S is 

the 'i~tQrmation desQli~ m ~~hs 2(a)(1l through 2(a)(7).<>f 

Articlf!;2 of~s Agr~ent, ;ex~tJor gr?,~1·i>~ described in 

subparagraph.2(a)(5)(B) of Article 2 of this Agreement; and 

· (3) the information to be o.btainedand exchanged with.respect to2016.and 

spl;>~e~ y~ is th~ inf n fiescriqed in subparagraphs 2(a)(l) 

through ~aj(7) of Article 2 of this ~~ment; 

In the case of the United SUs,t~ the.information to be obtained and exchanged 

with respect to .. 2(ll4 and sub~l.lent yeats is all of the information identified 

in subparagraph 2(b) of Article 2 of this Agreement. 

4. Notwithstan<Jin,g :J?Magrilph 3 ofthisf\.J:'Q~Ie, ~respect t0 .each ReportableAc~unt 

that is maintained by a Reporti~g Finan,cial Institution as fiUil~·~o, ·2o 14, and Sl:lbject to 

paragraph 4 of Article 6·ofthisAgreement, the Pal'ties are not required to obtain and include 

in the exchanged information the Liechtenstein TIN or tbe U;S. TIN, as appliectble, of any 

rt!~ev~m ~rs~n usuch ~yer idcntiWqg~nUll1ber is:~t iflct}le,~c;ords of,theReporting 

Financial Institution. m·,Jhqlt~~:the,f?art,ies.sh~;Qll~:~·~el\l_4e inJh~e?W~e<l 

jnfonnation the date on>irth of the relevant person, ·if the Reporting Financial Institution has 

such date ofbirth in its records. 

5. Subj~ to paragraphS 3 and 4 ofthis Artictle •. itie intomation. described.inArticle 2 of 

this~~~, ~.all be~si}~~~ct?4~l)•.m®~;~~·~~f!Q~.~m~~ear to 

which tile mformiltion rtlate~ . . . . . ' . ~ . . . . . 

o.. . . 1'he·C,o111pet~·~'f~~rt~~~~Pl·a#~~:-.§~~ .ente! ~~:~ a~eP.t '1f ~g~~~;~!;f w~.'l:n~,~~~;pr9Wded.for JnAtti~lelO of the TIEA, as amended by the ProtocOl, WhtOh shall• 

a) 

b) 

c) 

e:staPU®. tllePtoce<lures fQr.tbe automatic ~~ge.obligations described in 

Article2 ofthisAgreemen~ 

prescribe rules and procedures as may be necessary to implement Article 5 of 

this Agreement; and 

establish as necessa.rY procedums for the. exchanse .of the information reported 

under subparagraph 1 (b) of Article 4 of this Agreement. 

7. All information exchanged shall be subject to the confidentiality and other protections 

provided for in the TIEA, as amended by the Protocol, including the provisions limiting the 

use of the information exchanged. 
8. Following entry into force of this Agreement, each Competent Authority shall provide 

written notification to the other Competent Authority when it is satisfied that the jurisdiction 

of the other Competent Authority has in place (i) appropriate safeguards to ensure that the 

information received pursuant to this Agreement shall remain confidential and be used solely 

for tax purposes, and (ii) the infrastructure for an effective exchange relationship (including 

established processes for ensuring timely, accurate) and confidential information exchanges, 

effective arid reliable communications, and demonstrated taJl.abilities to promptly resolve 

questions and concerns about exchanges or requests for exchanges and to administer the 

provisions of Article 5 of this Agreement). The Competent Authorities shall endeavor in good 

faith to meet, prior to September 2015, to establish that each jurisdiction has such safeguards 

and infrastructure in place. 

9. The obligations ofthe Parties to obtain and exch.a.Qge information under Article 2 of 

this Agreement shall take effect on the date of the later ofthe Written notifications described 

in paragraph 8 of this Article. Notwithstanding the foregoing, if the Liechtenstein Competent 

Authority is satisfied that the United States has the safeguards and infraStructure described in 

paragraph 8 of this Article in place, but additional time is necessary for th.e U.S. Competent 

Authority to establish that Liechtenstein has such safeguards and· infrastructure in place, the 

obligation of Liechtenstein to obtain and exchange information under Article 2 of this 

Agreement shall take effect on the date of the written notifieationprovided. by the 

Liechtenstein Competent Authority to the U.S. Competent Authority pursuant to paragraph 8 

of this Article. 

10. This Agreement shall terminate on September 30,.2015, i.f.Atticle.2 orthisAgreement 

is not in effect for either Party pursuant to paragraph 9 ofthisArtiete by that date. 

Article4 

Application of FATCA to Liechtenstein Finandallnstitutions 

1. Treatment of Reporting Liechtenstein Financial Institutions. Each Reporting 

Liechtenstein Financial Institution shall be treated aS complying With, ilnd not subject to 

withholding under, section 1471 of the U.S. Internal Revenue~ Code if Liechtenstein complies 

with its obligations under Articles 2 and 3 of this Agreement vntli. f'espeet to sucn Reporting 

Liechtenstein Financial Institution, and the Reporting LiechteilSt~n Financial InstitUtion: 

a) 

b) 

c) 

d) 

identifies u~s. Reportable Accounts and reports annually to the Liechtenstein 

Competent Authority1he information required to be reported in subparagraph 

2(a) of Article 2 of this Agreement in the time and manner described in Article 

3 of this Agreement; 

for each of 2015 and 2016, reports annually to the Liechtenstein Competent 

Authority the name of each Nonparticipating Financial Institution to which it 

has made payments and the aggregate amount of such payments; 

complies with the applicable registration requirements on the IRS FATCA 

registration website; . 

to the extent that a Reporting Liechtenstein Financial Institution is (i) acting as 

a qualified intermediary (for purposes of section 1441 of the U.S. Internal 

Revenue Code) that has elected to assume primary withholding responsibility 
under chapter 3 of s1,1btitle A of the U.S. Internal Revenue Code, (ii) a foreign 

partnership that has electe(i to act as a, withhol<fing.f~reign]~er;ship (for 

P~~~r~oth sections 1441 and 1471 of. the U.S.~ !R~• Code), 

or (in) ~f()fetan ~tthat luls elected t9 ru:t as.a w;ithholdingforeimx :trust (for 

~ses.<>fboth sectiens 1441 and 1471 0ftheU .• S.h\~,~event.Je Code), 

mthholds 30 percent ofany U.S. Se~e Witbholdable PaymenttO'.any 

Nonparticipating Financial Institution; and 

e) in the ca$e of a Reporting Liechtenstein Financial Institution that is not 

desCfihed in silbp~h l(cl) of this Article and thpt·maJs~a payment of, or 

ac~ as~ i~tennediacy with r~ct.tota U~S. So~ Witbholdable Payment 

to any Nenparticipating Financiallnstitm;iont the ~.Uiechtenstein 

Fi.naQcial.~'9tioJJ ,provides·to ~Y immediate payornfsuchu.s. Source 

Withholdable Payment the info~on requir~ for w;ithholdip,.gandreperting 

to occur with.~pect to such payment. 

Notwithstanding the foregoing, a Reporting Liechtenstein Financial Institution with respect to 

which the cenditions ofthis ~h 1 are not satisfied shall not be $Ubjeet to withholding 

undel",s~pn 1:471 ofthe U.S. Internal Revenue Code unlesssuch.Rql0ttip.gLiechtenstein 

FinanCiailn¢~ution is treated by the IRS as a NonpartiCipating FinanciaUnstitution pursuant 

to subpamgraph 2(b) of Article 5 of this Agreement. 

2. Supension gf Rgles Relatiug tg R&s!Jeitr;ant&ecount§.,: Th~ U~ States shall 

n9t~~:,a.~rting.ltieeh~ .. Finan0ial.~tution·to ~~14 ta}f;u,t)(ier section 1471 

or 1472 .Of the U.S. Int~al Reven'"e .C(),d<rwith~io.\~~count.he;IO.;Q¥ a recalcitrant 

account holder (as defined in section 1471 (d)(6) of the U$~ Intetnal Reven~ Code), er .to 

clo~. ~Jl.Ch:accol,lttt, if~ :o.~. Cp~tentA~~ives~e;inform,a~.~.~~ in 

subparagmph2{a)of Article~ of thiS Agreement. sqbject to the proVi$i()ns ofArtie1e;3 of this 

Agreement, with respect to such account 

3. . :~nB!Ae~t·gj:llcehtfastein Retif!ID.it:~~ .. ~.:vm~Staies shall 

.~.~.~~~ '· ·.· ··· · · ". ·u ·· 'JW · . ·· ··· .ben-C • • · ·~as ·. · · ~ ·.tor · · sesof •..... !~.~~enmt .. ,.~dal~. ~ putpo 

·secu6JlS.l~li :and 1472 Of~,u,~-:1~~ ~e)ille·.~~~~~~rementplans desCriD«i in Annex n .. For this .purpos~ a Uechtenstein retitement·planinc1udeS an Bntity 

b.t: .... l.~ ·I. . ted • . d .......... 1--+.0.A b' . T .:.;.; ... ~.dr. ..... i ..,.....,.A--:~.. ntractual esta ~~u: •. ~. ~an .,.~""""· Yt:LIW\il'-~~~ njmr,li~~~~~iJO . . or lQg~~e.m~t,opetated to.p!()vide pension or:retireJnent,J)ene:fi'(s or~;jncome for 

providing'·S11ch benefits under the laws o(Uechtenstem:and regulated with respect to 

contributions. distributions. reporting, spensorship, and taxation~ 

4. identification and Treatment ofOther.Peemed..ComplianUf&pd Exempt 

Denetieiat Owners. The United States. shall treat eachNon.:Rept>rting Liechtenstein 

Financial Institution as a deemed-compliant FFI or as an exempt beneficial, owner, as 

appropriate, for purposes of section 1471 of the U.S. Internal Revenue Code. 

5. Special Rules Regarding Related Entities and Bran~bes That Are 

Nonparticipating Financial Institutions. If a Liechtenstein Financial Institution, that 

otherwise meets the requirements described in paragraph 1 of this Article or is described in 

paragraph 3 or 4 of this Article, has a Related Entity or branch that operates in \i jurisdiction 

that prevents such Related Entity or branch from fulfilling the requirements of a participating 

FFI or deemed-compliant FFI for purposes of section 1471 of the U.S. Internal Revenue Code 
or has a Related Entity or branch that is treated as a Nonparticipating Financial Institution 

solely due to the expiration of the transitional rule for limited FFis and limited branches 

under relevant U:S~ Treasury Regulations, such Liechtenstein Financial Institution shall 

continue to be in oompliance with the terms of this Agreement and shall ~ontinue to be 

treated as a deemed-cotnptiant FFI or exempt beneficial owner, as appropriate, for purposes 

of section 1471 of the U.S. Internal Revenue Code, provided that: 

a) the Liechtenstein Financial Institution treats each such Related Entity or 

branch as a separate Nonparticipating Financial Institution for purposes of all 

the rep<)rting and withholding requirements of this Agreement and each such 

Related Entity or branch identifies itself to withholding agents as a 

Nonparticipating Financial InStitution; · 

b) each such Related Entity orbranch·identifies its U.S. accounts and reports the 

information with respect to those acccunts as required urlder section 1471 of 

the U.S. Internal Revenue Code to the extent permitted under the relevant laws 

pertaining to the Related Entity or branch; and 

c) such Related Entity or branch does not specifically solicit U.S. accounts held 

by persons that are rtot resident in the jurisdiCtion where such Related Entity 

or branch is located or accounts held by Nonparticipating Financial 

Institutions that are not established in the jurisdiction where such Related 

Entity or branch is located, and such Related Entity or branch is not used by 

the Liechtenstein Financial Institution or any oth~rRetated Entity to 

circurmtent tbe·obligations \mder 1his Agreement or under section .1471 of the 

U.S. ltrtemat Revenue Code, as appropriate~ 

6. Cpordina&n'ofTimfng. Notwithstanding paragraphs 3 and 5 of Article 3 ofthis 

Agreement: 

a) 

c) 

d) 

Liechtenstein shall not be obligated to obtain and exchange information with 

respoot to a calendar. year that is prior to thercal@dar year Wfth.i'eSPeCt to 

which similar information is requited rto be rep6rtea to the tR.s by participating 

FFis pursuant to relevant u:s. T~ruyR.egulations; 

Liechtenstein shalt not be db ligated to begin exchanging infonnation prior to 

the date by which participating FFis ·arb required to 'I'epbrt similadnformation 

to the IRS under relevant U~S.Treasury Regulations; 

the United States shall not be obligated to obtain and exchange information 

with respeet to a calendar year truit is prior to the first calendar year with 

respect to which Liechtenstein is required to obtain and exchange information; 

and 

the United States shall not be obligated to begin exchanging information prior 

to the date by which Liechtenstein is required to begin exchanging 

information. 

7. Coordination ofDefinitions with U.S. Treasury Regulations. Notwithstanding 

Article 1 of this Agreement and the definitions provided in the Annexes to this Agreement, in 

implementing this Agreement, Liechtenstein may use, and may permit Liechtenstein 
Financial Institutions to use, a definition in relevant U.S. Treasury Regulations in lieu of a 

corresponding definition ~in this Agreement, provided that such application would not 

frustrate the purposes of this Agreement. 

ArticleS 

Collaboration on CompHance and Enforcement 

1. Minor and Administrative Errors. A <i:ompete1;1t Authority shall notify·the Competent 

Authority of the other Party when the frrst-mentioned Competent Authority has reason to 

believe.that administfative errors or other minor errors may have led to incorrect or 

incomplete info~on,.J:q>arting or resulted in other infringements of this Agreement. The 

Competent Authority of such other Pa,rty shall apply. its domestic law {includin,g applicable· 

penalties) to obtain corrected and/or complete information or to resolve other infringements 

of this Agreement. 

2. Significant Non-Compliance. 

a) A CompetentAuthority shall notify .the Competent Authority of the other Party 

when the first-mentioned Competent Authority has determined that there is 

significant non-compliance with the obligations under this Agreement with 

respect to a Reporting Financial Institution in the other jurisdiction. The 

Competent Authority of such .other Party sballapply its domestic law 

(inclu~ applicable penalties) to address the significant non-compliance 

described in the notice. . ' ' '' ' ' ,' ' ' ' ~ 

b) rt·in the case of a Reporting Liechtenstein Financial Institution, such 

enforcement actions do not re$0lve the non-compliance within a period of 18 

m~ after notification of signi{icantnon-complianee is first provided, the 

United 'Sta'tes Snail treat the RePorting Liechtenstein Financial Institution as a 

Nonpat(icipatmg Financi~ lnstitution PU!$~t to this sub~h ~(b)~ 

3. 'ReUag~ oft 't)iigl fAdY Service Provides~ ~cA'~~lJ)ay~pw~ FinanQiallns.ti~o~.ctQ ~e.ib,frdparty scmce proviil<srs to fulfill the obli.gatio~;itnp(>sedo~ 

such R#portmg Fiilal)cim~onsby a.PatfY~,as ~n~latec;llp.~.~~-!Jitdiese 

obligations shall remam the reSponsibility ofthe Repnrting Financial In~tutiOD$. 

4. Prevention of Avoidance. The Parties shall implentent as necessary reqqi,rem¢nts to 

prevent Flnanctai:fustitunons ftom adopting practices intended to circumventthe.· reporting 

required under this A~eement. 

Article 6 

Mutual Commitment to Continue to Enhance the Effectiveness of Information 

Exchange and Transparency 

1. Reciprocity. The Government ofthe United States acknowledges the need to achieve 

equivalent levels of reciprocal automatic information exchange with Liechtenstein. The 

Government of the United States is committed to further improve transparency and enhance 

the exchange relationship with Liechtenstein by pursuing the adoption of regulations and 

advocating and supporting relevant legislation to achieve such equivalent levels of reciprocal 

automatic information exchange. 
2. Treatment of Passthru Payments and Gross Proceeds. The Parties are committed 

to work together, along with Partner Jurisdictions, to develop a practical and effective 

alternative approach to achieve the policy objectives of foreign passtbru payment and gross 

proceeds withholding that minimizes burden. 

3. Development of Common Reporting and Exchange Model. The Parties are 

committed to workitig with Partner Jurisdictions, the Organisation for Economic Cooperation and Developmen~ arid the European Union, on adapting the terms of this 

Agreement and other agreements between the United States and Partnet Jurisdictions to a 

common model for automatic exchange of information. including the development of 

reporting and due dHigence:mandru-ds for financial institutions. 

4. Documentation of Accounts Maintained as ofJunc 30, 2014. With respect to 

Reportable Accounts maintained by a Reporting Financial Institution as of June 30, 2014; 

a) The United States commits to establish, by January I, 2017, for reporting with 

respect to 2017 and subsequent years, rules requiring Reporting U.S. Financial 

Institutions to obtain and report the Liechtenstein TIN of each Account Holder 

of a Liechtenstein Reportable Account as required pursuant to subparagraph 

2(b)( l) of Article 2 of this Agreement; and · 

b) Liechtenstein commits to establish, by January 1, 2017, for reporting with 

respect to 2017 and subsequent years, rules requiring Reporting Liechtenstein 

Financial Institutions to obtain the U.S. TIN of each Specified U.S. Person as 

required pursuant to subparagraph 2(a)(l) of Article 2 of this Agreement. 

Article7 

ConsiSten:ey in the Application of FATCA to Partn.er Jurisdictions 

1. Liechtenstein shall be granted the benefit of any more favorable terms under Article 4 

or Annex I of this Agreement relating to the application of FATGA to Liechtenstejn F~cial 

Institutions afforded to an<rtbet'PsrtherJurisdi~tion underil signed bilateral agrec;ment 

pursuant to·wmclt the.ether Pitrtner Jurisdiction oollln)itSto underiake tlle .. sanie obligations as 

Liechtenstein desctil)ed in Articles 2 and 3 of this Agreemen~ and subject to the $ftri1e terms 

and conditions as described thmirt and in Ai1icles 5 through 9 of this Agreement. 

2. The United States shall notify Liechtenstein of any such more favorable terms, and 

such more favorable terms shall apply automatically tinder this Agreement as if such tenns 

were specified in this Agreement and effective as of the date of the erttty into force ofthe 

agreement incorporating the mote favorable tenns, unless Liechtenstein declines the 

application thereof. 

Article 8 

Consultations and Amendments 

1. In case any difficulties in the implementation of this Agreement arise, either Party 

may request consultations to develop appropriate measures to ensure the fulfillment of this 

Agreement. 
2. This Agreement may be amended by written mutual agreement ofthe Parties. Unless 

otherwise agreed upon, such an amendment shall enter into force through the same 

procedures as set forth in paragraph I of Article 10 of this Agreement. 

Article 9 

Annexes 

The Annexes form an integral part of this Agreement. 

Article 10 

Term of Agreement 

1. This Agreement shall enter into force on the date of Liechtenstein's written 

notification to the United States that Liechtenstein has completed its necessary internal 

procedures for entry into force of this Agreement or the date of entry into force of the 

Protocol, whichever is later. 

2. Either Party may terminate this Agreement by giving notice of termination in writing 

to the other Party. Such termination shall become effective on the first day of the month 

following the expiration of a period of 12 months aft~r the date of the notice of termination. 

3. The Parties shall, prior to December 31, 2016, consult in good faith to amend this 

Agreement as necessary to reflect progress on the commitments set forth in Article 6 of this 

Agreement. 

Done at Vaduz, this 16th day of May, 2014 in duplicate in the English language. A German 

language text shall be prepared which shall be considered equally authentic upon an 

exchange of diplomatic notes between the Parties confirming its conformity with the English 

language text. 

FORTHEGOVERNMENTOF 

THE UNITED STATES OF AMERICA: 

FORTHEGOVERNMENTOFTHE 

PRINCIPALITY OF LIECHTENSTEIN: 
ANNEX I 

DUEDII..IGENCE~OJJLIGA'flONS FOR]DEN'I'IFYING AND REPORTING ON U.S. 

REPORTABLE ACCOUNTS,AND ON'PAYMENTS TO aRTAIN 

NoNPARTICIPATlNG FiNANciAL lNSTrruTIONS 

I. General. 

A. Liechtel1Stein shall l.'equire that Reporting Liechtenstein Financial Institutions 

apply the. due diligence procedures contained in.thisAnnex I to identify U.S. 

Reportable Accounts and accounts held by Nonparticipating Financial Institutions. 

B. For.p~es of the Agreement, 

1. All dollar amounts are in U.S • .dollars and shall be read to include the 

equivalent in other currencies. 

2. Except as otherwise provided herein, the balanc~ or· value of an 

account shall be: determined as of the last day of the calendar year or other 

appropriate reporting period. 

3. Where. a ~alanceor value th(eshold is to be. determined as of June 30, 

2014 upderthisAnnexl, .the relevant balance or value shall be determined as 

of that day or the last day of the reporting period ending immediately before 

June 30, 2014,: and ~ere a~ or value t;hreshold is to be determined as 

of the last ~day of a calendar year under this Annex I, the relevant balance or 

va1ue.sbltlU~~;(i~~J;l,S of the J.ast;day of· the calen,daf.year or other · 

•· app · ro p dare .. ~ ~ .. l1iii gpe. · . · noa ,, 

4. StibJecl to subpara~h B{l) ofsectionll Qf:thi~A.ml~l, an~unt 

shall be treated as aU .s. Reportable Account'beginning as of the date it is 

i~ntitied•~ ~U() tJte.d~sdilig,epce prQced~ in this Annex I. 

5.. UJ:ll~ ~~ proVide(i.infO)Wltion with respecUo a U.S. 

Reportable Acicount shall be reported annually in the calendar year following 

the year to which the information relates. 

C. As an alternative to 'the procedures described in each section ofthisAnnex I, 

Liechtenstein may permit Reporting Liechtenstein Financial Institutions to rely on the 

procedures described in r:e1ev~t U.S. Treasury Regulations to establish whether an 

account is a U.S. Reportable Account or an account held by a Nonparticipating 

Financial Instituti9~ Li~h~tejn mey pem{itReportin,g Liechtenstein Financial 

Institutions to make such election separately for each section of this Annex I either 

with respect to all relevant Financial Accounts or, separately, with respect to any 

clearly identified group of such accounts (such as by line of business or the location 

of where the account is maintained). 

II. Preexisting Individual Accounts. The following rules and procedures apply for 

purposes of identifying U.S. Reportable Accounts among Preexisting Accounts held by 

individuals (''Preexisting Individual Accounts"). 
A. Accounts Not Required to Be Reviewed, Identified, or Reported. Unless 

the Reporting Liechtenstein Financial Institution elects otherwise, either with respect 

to all Preexisting Individual Accotints or, sepatately, with respect to any clearly 

identified group ofsuch accounts, where the implementing rules in Liechtenstein 

provide for such an election, the following Preexisting Individual Accounts are not 

required to be reviewed, identified, or reported as U.S. Reportable Accounts: 

1. Subject to subparagraph E(2) of this section, a Preexisting Individual 

Account with a balance or value that does not exceed $50,000 as of June 30, 

2014. 

2. Subject to subparagraph E(2) ofthis section, a Preexisting Individual 

Account that is a Cash Value Insurance Contract or an Annuity Contract with a 

balance or value of$250,000 or less as of June 30,2014. 

3. A Preexisting Individual Account that is a Cash Value Insurance 

Contract or ,an Annuity Contract, provided the law or regulations of [F ATCA 

Partner] or the United States effectively prevent the sale of such a Cash Value 

Insurance Contract or an AnnuitY Contract to U.S. residents (e.g .• if the 

relevant Financial Institution does not have the required registration under 

U.S. law, and the. law of Liechtenstein requires reporting or withholding with 

respect to insurance products held by residents of Liechtenstein). 

4. A Depository Account with a balance of $50,000 or less. 

B. Review Procedures for Pregisting Individual Accounts With a Balance or 

Value as of June 30, 2014. that Exceeds $50;000 ($2501000 for a Cash Value 

Insurance Contract or Annuity Contract), But Does Not Exceed $1;000,000 

<"Lower Value AAAounts"l. 

1. ElectrontcReeord'Searclt. The Reporting Liechtenstein Financial 

Institution must review electronically searchable data maintained by the 

Reporting Liechtenstein Financial Institution for any of the following U.S. 

indicia: 

a) Identification ofthe Account Holder as a U.S. citizen or 

resident; 

b) Unambiguous indication of a U.S. place of birth; 

c) Current U.S. mailing or residence address (including a U.S. 

post office box); 

d) Current U.S. telephone number; 

e) Standing instructions to transfer funds to an account maintained 

in the United States; · 

f) Currently effective power of attorney or signatory authority 
granted to a person with a U.S. address; .or 

g) An 'm-cam--o:f' or "h6ld.maii'- add.ress that is the sole address 

the R~~Li~~em.P~I~stiMion has on file for the 

Aecouilt?Holder. In the case·ofa PreexiStihg Individual Account that is 

~ Lo~ Yf.lllle ~CC9unt. an "in':qare--of~ address outside the United 

s~ -or ·~hold.mail"ttddress shan not be. treated as u.s. indicia. 

2. Ifnoneofthe U~S. indicia listed in subparagraph B(I) of this section 

at~ disco::vered in the electronic search, then no further action is required until 

there.is a.~han~ in•9ircumstan~ ~tl;eSUlt.sin one or more U.S. indicia 

being associated with the account, orthe,acco;untbecomes a High Value 

Account described in paragraph D of this section. 

3. If any of the U.S. indicia listed in.subparagraph B( 1) of this section are 

discovered in the electrOnic search, or ifthere4s a change in circumstances 

that results in one or more U.S. indicia being associated with the account. then 

the Reporting Liechtenstein Financial Institution must treat the account as a 

U.S. ReportableAccpuntunlessiteleetsto apply subparagraph B{4) ofthis 

section and one ofthe exceptions in such subparagraph applies with respect to 

that a®Qunt. 

4, twi~~a,find:Q)g gf.U .. S. indicia under subparagraph B( 1) of 

this section. a Reporting Liechtenstein Financial Institution is not required to 

treat an account as a U:S. ReportableAccQuntif: 

.a) .~ the;Account &,ldet.inf9rmation unambiguously 

i;u}i~lc;~J fl~ p~~ce.of :t,b:tl}.~ ~.R9W11in& .l.,i~htenstein Financial 

Institutb.»Hlbtain~ <?":~,pmvi<>~f teviewed and maintains a record 

o(: 

UJ .• ,4~(f~~~~~the ~C,COllm Holder is neither a 

U .. $ .. a~p.pr~a u;~. ~UJ:eAt.(q:r;tap,purposes (which may be 

on an'IRSForm W·S:orothersinillar,agreed form); 

(2) . A no~U.S. passport or other government-issued 

identificatiQn evidenehm.the:Account Holder's citizenship or 

nationality in a country "other than the United States; and 

(3) A~py of the Account Holder's Certificate of Loss of 

Nationality ofthe United States or a reasonable explanation of: 

(a) The reason the Account Holder does not have 

S\.!Ch a certificate despite relinquishing U.S. citizenship; 

or 

(b) The reason the Account Holder did not obtain 

U.S. citizenship at birth. 

b) Where the Account Holder information contains a current U.S. 
mailing ()r residence address, or one or more U.S. telephone numbers 

that are the only telephone numbers assocwted with the account, the 

Reporting Liechtenstein Financial Institution obtains, or bas previously 

reviewed and maintains a record of: 

( 1) A self-certification that the Account Holder is neither a 

U$. citizen nor a U.S. resident for tax purposes (which may be 

on an IRS Form W -8 or other similar agreed form); and 

(2) Documentary evidence~ as defined in paragraph D of 

section VI ofthis Annex I, establishing the Account Holder's 

non-U.S. status. 

c) Where the Account Holder information contains standing 

instructions to transfer funds to an account maintained;, the United 

States, the Reporting Liechtenstein Financial Institution obtains, or bas 

previously reviewed and maintains a record of: 

(1) A self-certification that the Account Holder is neither a 

U.S. citizen nor a U.S. ~esident for tax purposes {which may be 

on an IRS Form W-8 or other similar agreed form); and 

(2) Do~umentary evidence, as defined in paragraph D of 

section VI of this Annex I, establishing the Account Holder's 

non .. u.s. status. 

d) Where the~Aecount Holder information contains a currently 

eifoctlvep()Wer of attorney or slgntitory authority granted to a person 

With ti u.s: addreSs, has an 7"iit-cari!-Of" address or "hold mail" 

address that is the sole address identified for the Account Holder, or 

has one or more U.S. telephone numbers (if a non-U.S. telephone 

number IS also tiSsoclated with tht account), the Reporting 

LieehtenstemFmancial Institutiori obtains, or has previously reviewed 

and maintains a record of: 

(1) A self-certification that the Account Holder is neither a 

U.S. citizen nor a U.S. resident for tax purposes (which may be 

on an'IRS Form W-8 or other similar agreed form); or 

(2) Documentary evidence, as defined in paragraph D of 

section VI of this Annex I, establishing the Account Holder's 

non-U.S. status. 

C. Additional Procedures Applicable to Preexisting Individual Accounts 

That Are Lower Value Accounts. 

l. Review of Preexisting Individual Accounts that are Lower Value 

Accounts for U.S. indicia must be completed by June 30, 2016. 
2. . If there is a.ehange of circwnstances with respect to a .Preexisting 

Individual Accoontthat is aLower Value ACC()Wlt~,resultsJ~ one or more 

U.S. u;_dicia,descrihea m subparagraph B(l) :ofthls section being associated 

with the:acC()urit ~"P:~~ll.q,q~g U~jn Finat1cial Insti~tion must 

treat the ,acoounb1S'a u.s. RepottableACC<)untunless subparagraph B( 4) of 

this sectioi) appli~. 

3. Except for D.epositoryAccounts described in subparagraph A(4) of this 

section, any Preexisting Individual Account that has been identified as aU .S. 

ReportableAccount .. -qn'der thissecti()n.shall be :treated a:s aU$. Reportable 

Accoun~ in all s~eqq~n.tyears. unl~ the Account Holder ceases to be a 

Specified U.S. Pers~h. 

1. Electrgnie Record Sepreh. The Reporting Liechtenstein Financial 

Institution must review electronjcally searchable 4atat;naintained by the 

Reporting Liechtenstein Financial Institution for any of the U.S. indicia 

describedinsubpara~ph B(l) ofthissection. 

2. Paper Record Searclt. lfthe Reporting Liecbtenstein Financial 

Institution~s:.eleotrOOi~b" s~hable ~·~~IwJe;fjelds for. and capture all fth .~ ~·· • .. ~.;.;: (f . ·~....;.~· ~;~~· D". £ . ·. th · q .. e.Jn~-..,_;~~~> ~·~ ~n. ~~ .. ~~"",00. ·. ,3) G.. :this section, en no 

further paper~·~ Js ~~· .Iftbe·e'l,~~:d~tdilases do not 

capture. aJlofthis~Ql!p~tl()n, •tblsn·~ ~ltt~ca ~gh Value Account, the ~t'ttrin; Lie¢h•...Wc:m.i'ft }.":-.,...n: .. J. T~..m...+< · . . . ·· ,.,.J.,.,.,. '• ,fu :vru~,~ ... · ~~!'¥ ·~."'"'~~~"!·~~'f~"" ... 91VP,U~t~.~~w. ecurrent 

custorner~.~~r:t(lthe.elWm1 ~ot~~~~~t customer 

master file. the foll~~ng doeWJJ.en~ associ~94;~tltJ.h~.~unt.and obtained 

by the Reporting LiechtenStein Financial InstitittiOn witbin:the Jast five years 

for any oftb.e {J.S. indicia~~~.~~~;B,,l)ofthis section: 

a) . 'O,le'·most:~t ~~ eYj;dotice collected with respect 

to til¥ a(X:()Uf#; . 

b) Them,estrecentaccount'<)f'Cning;Oont.t"actordocumentation; 

c). The :most recent documentation .obtained by·the Reporting 

Liechtenstein Financial Institution pursuant to AMUKYC Procedures 

or for other regulatory purposes;· 

d) Any poWer of attorney or signature authority forms currently in 

effect; and 

e) Any standing instructions to transfer funds currently in effect. 

3. Exception Where Databases Contain Sufficient Information. A 

Reporting Liechtenstein Financial Institution is not required to perform the 

paper record search described in subparagraph 0(2) ofthis section if the 
Reporting Liechtenstein Financial Institution's electronically searchable 

information includes the following: 

a) The Account Holder's nationality or residence status; 

b) The Account Holder's residence address .and mailing address 

currently on file with the Reporting Liechtenstein Financial Institution; 

c) The Account Holder's telephonenumber(s) currently on file, if 

any, with the Reporting Liechtenstein Financial Institution; 

d) Whether there are standing instructions to transfer funds in the 

account to another ac~unt (including an account at another branch of 

the Reporting Liechtenstein•Financial lnstitution or another Financial 

Institution); 

e) Whether there is a current ''in.:.care-of'·address or "hold mail'' 

address fortheAccount Holder; t:ind 

f) Whether there is any power of attorney or signatory authority 

for the account. 

4. Relationship Manger Inquiry for Actual Knowledge. In addition 

to the ~el~tronic ·and pa~ rtcord searches described· above. the Reporting 

LieChtenstein Financial InstitUtion must treat aS a U.S. Rq>Ortable Account 

any High.Value Aooount assigned to a relationship manager (including any 

Financial Accounts aggregated with such High Value Account) if the 

relationship manager has acttuil ktiowledge that th~Account Holder is a 

SpecifiedU.S. Person. 

5. Effect ofli'iuding U.S •. fudicla. 

a) Ifnoneofthe U.S. indicia listed in subparagraph B{I) of this 

section are discovered in the enhanced review ofHigh Value Accounts 

described above, and the account is not identified as held by a 

Specified U.S. Person in sUbparagraph D{4) ofthis section, then no 

further action is required until there is a change in circumstances that 

results in one ot more U.S. indicia being associated with the account. 

b) If any of the U.S. indicia listed ih subparagraph B( 1) of this 

section are discovered in the enhanced review of High Value Accounts 

described above, or if there is a subsequent Change in circumstances 

that resUlts in one or more U.S. indicia being associated with the 

account, then the Reporting Liechtenstein Financial Institution must 

treat the account as a U.S. Reportable Account unless it elects to apply 

subparagraph B(4) of this section and one of the exceptions in such 

subparagraph applies with respect to that account. 
.c)· .Except for DepoSitory Accounts described in subparagraph 

A( 4):Qfitbis,~on. any Pr~isting Individual Account that has been 

id.en,tified as a U.S. RepOrtable ACCOunt under this Section shall be 

treated.Mau,s. &p~:n-tatileAcco~t;in.all subsequent·y~. unless the 

Account Holder cea$~10 be a, Specified u.s. Person; 

E. Additional Procedures Apolicablecto ·HigbValueA~eounts. 

1. If a Preexisting Individual Account is a.High Value.Account as of June 

30, 2014. the Rep<>tting Liechtenstein .Financial Institution must complete the 

enhanced review procedures described in paragraph:D of this section with 

respect:to'Suebaccountby ~une 30,2015. Ifbased on this review such 

account is.identified as a U.:S. Reportable Account on .or before December 31, 

2014~·:the ~portlng UeQh~enstein Financial Instituti<>.n IPlJSt report tb.e 

required information. :®'out such account with. respeCt to·2014 in the first report 

on the account and on an annual basis tllereafter. In the case of an account 

idel:ltified as a U.S~ :Reportable Account after DeceiPber 31, 2014 and on or 

before June 30, .2015, the Reporting Liechtenstein Financial Institution is not 

required to report infufl'llation about such accol.lntwith res.pect to 2014, but 

must report information about the account on an annual basis thereafter. 

2. Ifa Preexisting Indi~dualAccountis nota High ValueAccount as of 

J~e 30,.2014, but becomes a.High.value ACC<).unt as ofthe last:day of2015 or 

any $Ubsequent waen4~ year. the Reporting Liechtenstein Financial 

InstitutipnmU$1 complete the enbmlced teview pr{lcedures.described in 

paragraph D of:this~o~.with:respect to. suo4aoooimf:within .$ix months 

after the last day of"the calendaryearin which die account becomes a High 

'ValueAccmmt. If:based on tbis·r»vi~"such account1s identified as aU.S. 

~le :A:qeotm~ the Reporting L:i~'Fimmciaiinstitution must 

report th:e.required information about sueh ~U!lt wlth respect to the year in 

which it i~:id~titied ~\a u~s;.~ttablC:A~t 8tla·~ub~ue.P,t years on an 

annual~§ '1lrtless•:theA:ceountHa1det tieas~tObei~rSpecified U.S .. Person. 

·J~ Once:a·IQ,poffins~i~hienStem~at .. fnstitution,applies.the 

~ced·~ew·pf'Ocedums~ip~~~D:ofthi~~~ to a High 

Value ACC()oot,'the·Repol'tifillJreohtetlSteili Fmanciil ~tion is·not 

reqUired tG l'~apply'sudh pfOCe(tures, other than the relationship manager 

inquiry described in subparagraph 0(4) ofthis Sectioh, to the Same High Value 

Account inany"subsequeittyear. 

4. If there is a change of circumstances with respect to a High Value 

Accotmt that results in: one or more U;S, indicia described in subparagraph 

B(l) of this section being assdciated with the account, then the Reporting 

Liechtenstein Financial Institution must treat the account as a U.S. Reportable 

Accotmt unless it elects to apply subparagraph B(4) of this section and one of 

the exceptions in such subparagraph applies with respect to that account. 

5. A Reporting Liechtenstein Financial Institution must implement 

procedures to ensure that a relationship manager identifies any change in 

circumstances of an account. For example, if a relationship manager is 
notified that the Account Holder has a new mailing address in the United 

States, the Reporting Liechtenstein Financial Institution is required to treat the 

new address as a change 'in circumstances and, if it elects to apply 

subparagraph 8(4) of this section, is required to obtain the appropriate 

documentation from the Account Holder. 

F. Preexisting Individual Accounts ThatHa:ve Bten Documented for Certain 

Other Purposes. ·A Reporting Liechtenstein Financial Institution that has previously 

obtained documentation from an Accoutlt Holder to establish the Account Holder's 

status as neither a U.S. citizen nor a U.S. resident in order to meet its obligations 

under a qualified intermediary, withholding foreign partnership, or withholding 

foreign trust agreement with the IRS, or to fulfill its obligations under chapter 61 of 

Title 26 of the United States Code, is not .required to perform the procedures described 

in subparagraph B(l) of this section with respect to Lower Value Accounts or 

subparagraphs D(l) through D(3) of this section with respect to High Value Accounts. 

III. New Individual Accounts. The following roles and procedures apply for purposes 

of identifYing U.S. Reportable Accounts among Financial Accounts held by individuals and 

opened on or after July l, 2014 ("'New Individual Accounts''). 

A. Accounts Not Required to Be Reviewed, Identified, or Reported. Unless 

the Reporting Liechtenstein Financial Institution elects otherwise, either with respect 

to all New Individual Accounts or, separately, with respect to any clearly identified 

group of such accountsy where the implenlenting rules 1n Liechtenstein provide for 

such:an election, the following New Individual Accounts are not required to be 

reviewed, identified, or reported as u~s. ReportableAccounts: 

I. A DepQsitory A®Ount unless the account balance exceeds $50,000 at 

the end pf .any calendar year or other appropriate rep0rting period. 

2. A Cash Value Insurance Contract unJ~ .the Gash Value exceeds 

$50t000 at: the end of .any calendar year or other appropriate reporting period. 

B. Other New.lndividualAccounts. With respect to New Individual Accounts 

not descn'bed in paragraph A nfth~ sect! on, upon a()count openirlg (or within 90 days 

after the end of the calendar year in which the account ceases to be d~cribed in 

paragraph A of~ ~tion), the Rewrting ~iecptenstein FiiUUlc.ial Institution must 

obtain a self-certification, which may be part of the account opening documentation, 

that allows the Reporting Liechtenstein Financial Institution to determine whether the 

Account Holder is resident in the United States for tax purposes (for this purpose, a 

U.S. citizen is conai<lered to be resident in the, United States for tax purposes, even if 

the Account Holder is also .a tax resident of anotller jurisdiction) and confirm the 

reasonableness of such self-certification based on the information obtained by the 

Reporting Liechte,nstein Financial Institution in connection with the opening of the 

account, including any documentation collected pursuant to AMUKYC Procedures. 

1. If the self -certification establishes that the Account Holder is resident 
in the United .States for tax purposes, the Reporting Liechtenstein .financial 

Institution m\lSt~tthe account.as.a U$. Reporta))le Account and obtain a 

sdt-cerillication.that inclu(ies ~,AcoountHol~~s.l.tS. TIN (which may be 

an IRS FopliW-9 oi<).thersllililar ~tonn), ·· 

2. 'JfiDe~is ·a®ange,<>fcii;C~eswi~ r~ect to a New Individual 

AecotUJl.that.~ theRe .. rting.~iecbt~ijn.Fimw.Qia!Jn5titution to know, . . . .. . '"· . . . . ,· ... Ji)~ .... .. . . . ' -.'."' 

orhavexeason to laiow, thafthe originatself..cerillioation is inoorrect or 

unreliaf:!le~ the Reporting .Li~t~ Financial.~tution cannot rely on the 

originalself-:eertifiooticmandtnusto~tllin.a valid~{..;certification that 

establ~hes wh<$er the Account Holder is a U.S. ci~ or resident for U.S. 

tax purposes. lfthe Reporting Liechtenstein Financial'Instiwti.on is unable to 

obtain a yali<J self-ce,rtific.atio~ the R~g; Liechtenstein Financial 

Institution m~ treat th~ account ~.a U.S. Reportable Account. 

IV. Preexisting Eatity Accounts. The following.rules and procedJ,Ires apply for purposes 

.g{identifying.U.S. ReportableAccounts and accounts held by Nonparticipating Financial 

Institutions among PreexistingAccounts held by Entities.e·Preexisting Entity Accounts"). 

A. Entity Accounts Not Required to Be Reviewed, Identified or Reported. 

Unless the ~J>q~,Lie'?hte{lstem Finan004 .WS~Wt\Qp,<).i~ 9therwise, either with 

respect to .all PreeXisting'Bntity Acoounts or, separately, with respect tO any clearly 

i<\elltitie4.·grpup:9('ucb;~qp;ts. ~ tQ.e .mw~~tingntl.~ in Liechtenstein 

pl'Q'Yide for such an el~tio~,aJ>reex~g JintityAcco;t.Ult }\!ith an account balance or 

val~ ~.99~ppt.~~~r~:5.9;®Q ~ nfJune,lO~ 2014;.i,;notrequired to be 

reView~ id~,ot tem~ ~a 1J~S~ Repo .. bl~.Acco~t until the account 

balance or value exc:eeds,$1,0ootooo. 

B. .Eptiw~~:toJRpyp. A~~,i~EntjtyAccountthathas 

an.~~~~~~~~.~-~~.~~g,J~•;~,9"2~14,and a 

Preexisti9g J::ntitx~~·~·n<?t ~;mg~~·~qfiJ®e30. 2014 b~t the 

accQurit ~ceorvatue:.Qf~PXcee<Js,$~~;:of)af$:q£~theilast.day of201S ot 

any subsequent calendatyeat; must be reviewed: in accord8Ilce with th~ procedure$ set 

fortbln~~ n:~f.~ .. s~~ 

<:.. ED.tier~M8B~tOWtndi.·Wmna.IJ-B!9uked· with 

respectto Preexisting Sftfity .Accounts aesciibed in patagfapli tf of this section, only 

acc()unts tbaf!U'e held ,1Jy one .at m0re .Entities that are.Speeifiec,l U:S. Persons, or by 

Passive ~NFFBs .. :with one or moreConttollin$-~ersons wh<):a:te U.S. citizens or 

residents, shall be ~.asu .. s .. ~ortableAccpqn~. lq,:~.dition, accQunts held by 

Nonparticipating: FinaneiaUnstitutions shall be tteatethiS accounts for which 

aggregate p~yn;tents·~·.a~~ in subpat'ag@ph l(b) Qf Article 4 ofthe Agreement 

are·reported to the Liechtenstein Competent Authority. 

D. Revie\V Procedures for Identifying Entity Accounts \Vith Respect to 

Which Reporting Is Required. For Preexisting Entity Accounts described in 

paragraph B of this section, the Reporting Liechtenstein Financial Institution must 

apply the following review procedures to determine whether the account is held by 

one or more Specified U.S. Persons, by Passive NFFEs with one or more Controlling 

Persons who are U.S. citizens or residents, or by Nonparticipating Financial 
Institutions: 

1. Determine Whether the Entity Is a Speeified U.S. Penon. ' ' ~ / 

a) Review information maintained for regulatory or customer 

relationship purposes (including information' collected pursuant to 

AML/KYC ProCeditres)to ~oteinlirie wnether the'ihfonnation 

indicates that the Account Hold~ is 'a U~S. Persdn. For this purpose, 

information indicating that the Acooilnt Hol<leds aU$. Person 

includes a U.S. place ofinoorpotatib'n or organization, or a U.S. 

address. 

b) If the information indicates thattH.eAcoount Holder is a U.S. 

Person, the Reporting Liechtenstein Pmanciat Institution must treat the 

acoount as a U.S. Reportable Account unless it obtains a selfcertification from the Account Holclet (wllicb may be on an IRS Form 

W -8 or W .:.9, or a similar agreed form), or reasonably determines based 

on information in its possession or that is publicly available, that the 

Account Holder is not a Specified U.S. Person. 

2. Determine Whether a Non-U.S. Entity Is a Financial Institution. 

a) Review information maintained for regulatory or customer 

relationship pmposes (mcllld,itlg mf:ormatien 'C{)llected pursuant to 

AMUKYC Proced:urc~s)'ttN.Itterttiine'Wbetberthe ihformation 

indicatestWittheAcoount Holdeds a Fmancfal Institution. 

b) If the. information indicates that the Account Holder is a 

Ftnanciallfilstitution, ~ot~.ft:erJ011ing:Li~ein Fmanciat 

Institution Verities the AcoounfPioldOt's Olobat; In~ediary 

ldentificati(ln Number-on thb1)U1)Hs1u~a IR.S·FFHisf, tHen the account 

isncit'al.:J:S. ReportableAceouht 

3. petermine Whether a FinanCial Jmntuttmt & a1!onpaJ1ieipating 

Financial Institution Paymenq to Which .AgrSubieet to J).gregate 

Ret!o~uiiaerSbBbmpph 1<bl~tf6~4'0f'the'~ment. 

a) Subject to subparagraph D(3)(b) ofthis sbetion, a R'Cporting 

Liechtenstein Finanelal Iristitutien'may detetrnine that the Account 

Holder is a Liechtenstein Financial· InstitUtion or other Partner 

JurisdiCtion Financial Institution if tHe Reporting Liechtenstein 

Financial Institution reasonably determines that the Acoount Holder 

has such status on the basis of the AcCotmt Holder's Olobal 

Intermediary Identification Number on tHe published IRS FFI list or 

otHer information that is publicly available or in the possession of the 

Reporting Liechtenstein Financial ltlstitution) as applicable. In such 

case, no further review, identification, or reporting is required with 

respect to the account. 

b) If the Account Holder is a Liechtenstein Financial Institution or 
other Partner Ju,risdiqtion Financial Institution treated by the, IRS as a 

Nonpartici~ting Firian~~JnstiMion, then the ~.count is not a U.S. 

R~portable Account, but payments to the Acoount Holder must be 

reported as contemplated in ·~})paragraph 1 (b) of Article 4 of the 

Agreement. 

c) If the Account Holder is llQt 11 Liechtenstein Financial 

Institution or other Partner Jurisdiction Financial Institution, then the 

Repo~g Liechtenstein Financial Institu,tion must treat the Account 

Holder as a Nonparticipating Financial Institution payments to which 

are repo~le under sub~graph,l (b) ofArticle 4 of the Agreement, 

unless the Reporting LieChtenstein Financial Institution: 

(1) Obtains a self-certification (which may bean an IRS 

Form W -8 or similar 11greed form) from the Account Holder 

that it is a certified .de<mled-complia:p,t:FFI, or an exempt 

beneficial owner, as those terms are defined in relevant U.S. 

T~ Regulations; or 

(2) In the case ·of a participating FFI ot registered deemedcompli,an~ FFI? .verifies. the J\.®o\lllt .flo•cter ~s Global 

Intermediary Identification·Nunibeton the published IRS FFI 

list. 

'f. DeteJ!!ig.e Whether an Aecoyt IJeld b>: an NfFE Is<a U.S. 

•R~bJ~unt. Wi\h~~t~~~~Jf9l~Qf~.P;reexisting Et#.iW 4\~\Ult that is ~(id~tine4.as either a iJ.$.,~erson or a Financial 

Insiitutio th R.l , rti Lie¢"-+ · · F. c:"'1 l ... ~~~o t identify·.(i) .· . :. n. .~ .epo, ~,., •u..'<~e.Ul .. wan~· ~~"'·~~ffiU;S 

Whether>the A®9untij:o~4er luis Co~trolling P~(ii) ,:Wl}~ the Aocount 

Holder is a Pa$Sive NF~~:and (lit') whether any o•fth~ CqntroJling Persons of 

, tlttlAWO.~t H.older is .. a U.S. ~"or res~nt. :lJ;v·-a:a!'tcinu the~" d ."· "· >tio the~, • .lJecht ·. · F'man·iJ'~ ·onmustfollow 

· ~J:l~1!.~~·p(4)(l[;:;ugll·D(4)!d) Af;is section in the 

. .Q~er ~.ost aP.WOPriate U1lder the cit;cumstan®s. 

a) Fpr pu,rp.o~$ofdetem)ining the,CO~W9ll~g fC!sons of an 

Account Bolder. a Reporting Liechtenstein Firianclal.lnstitution may 

rely on information collected and maintained pursuant to AMUKYC 

Procedures. 

b) For purposes of determining whether the AccOunt Holder is a 

Passive NFFE, the Reporting Liechtenstein Financillllnstitution must 

obtain a self-certification (which may be on an IRS Form W-8 or W-9, 

or on a similar agreed. form) from the Account Holder to establish its 

.status, unless it has information in its possession or that is publicly 

available, based on which it can reasonably determine.that the Account 

Holder is an Active NFFE. 

c) For purposes of determining whether a Controlling Person of a 
Passive NFFE is a U.S. citizen or resident for tax purposes, a 

Reporting Liechtenstein Financiallnstitution may rely on: 

{1) Information collected and maintained pursuant to 

AMUKYC Procedures in the case of a Preexisting Entity 

Account held by one or more NFFEs with an account balance 

or value that does not exceed $1 ,000,000; or 

{2) A self--certification (which may be on an IRS Form W -8 

or W-9, or on a similar agreed form) from the Account Holder 

or such Controlling Person in the case of a Preexisting Entity 

Account held by one or more NFFEs with an account balance 

or value that exceeds $1 ,000,000. 

d) If any Controlling Person of a Passive NFFE is a U.S. citizen or 

resident, the account shall be treated as a U.S. Reportable Account. 

E. Timing of R~view and Additional Procedures Applicable to Preexisting 

Entity Accounts. 

1. Review of Preexisting Entity Accounts with an account balance or 

value that exceeds $250,000as of June 30,2014 must be completed by June 

30,2016 . 

.2. ·. Review efPreexisfilll En~ty Accounts with an account balance or 

value that does not exceed $250,000 as of June 30, 2014, but exceeds 

$1 ;000,00011S ofDecembet 31 of201 5 ot any subsequent year, must be 

completed within six months after the·tast day of the calendar year in which 

1he accol.mt balance otvatue exceeds $1,000~000. 

3. Ifthete is a change·ofcircumstances with respectl() a Preexisting 

Entity A~ ~at causes'the R~porting Lieclitcn1Steiii Fnianclat Institution to 

lmow, or have reason to know, that the self-certification or other 

documentation assoeiated with ah account is incorrect or unreliable, the 

ReJ?O~ Liechtenstein Financial Institution mus.t redetermine tlie status of 

~e f:}cc(;urit in accordance with the procedut¢8 set fortli in paragraph D of tliis 

section. . 

V. New Entity Accounts. The following rules and procedures apply for purposes of 

identifying U.S. Reportable Accounts and accounts held by Nonparticipating Financial 

Institutions amotigFinancial Accounts held by Entities and opened.on or after July 1, 2014 

\'New Entity Accountsn). 

A. Entity Accounts Not Required to Be Reviewed, Identified or Reported. 

Unless the Repol1ing Liechtenstein Financial Institution elects otherwise, either with 

respect to all New Entity Accounts or, separately, with respect to any clearly identified 

group of such accounts, where the implementing rules in Liechtenstein provide for 

such election, a credit card account or a revolving credit facility treated as a New 

Entity Account is not required to be reviewed, identified, or reported, provided that 

the Reporting Liechtenstein Financial Institution maintaining such account 
implements J>Olici~ ·~d proced:ures· to prevent an account balance owed to ·the 

Account Holder. that exceeds $50,000. 

B. Dthet New ,Ep.fitf.Aecounts. ·With:respect to New Entity Accounts not 

®s<:ri®<MP.'P~p~.A oftbis section~ ~R~rtillg Liec~in F-cial 

Institution mUSt i!etCtii1ine whether th<' Account Holder is: (D a Specified U.S. 

l?ers,tJu; (ii),~ Liegbt~ F~iallllstitution:or other Partner Jurisdiction Financial 

Institution;{ili}.aP4i'ticipating FFI; a f.leemed~mpliant FFI~ or an exempt beneficial 

owner, as·tbose terms are.defmedin relevant U.S. Treasury Regulations; or (iv) an 

Active NFFE or Passive NFFE. 

1. ,SJfbject .to subparagraph, B(2) of this s~on, ~ Reporting. Li~tenstein 

Financial Institution may determine that the Aceount Holder .is an Active 

NFFE, a Liechtenstein Financial Institution, or other Partner Jurisdiction 

Financial Jnstitutio,;1 ifthe Reporting Li~l1t~f¥in Financial Institution 

reasonably d~iries that theAccountHolder lias such status on the basis of 

the Account Holder's Global Intermediary Identification Number or other 

ioformati9n that is.publicly available or in the possession of the Reporting 

Liechtenstein Financial Institution. as applicable. 

2. If the Account Holder is a Liechtenstein Financial Institution or other 

P~ Jl)tjSdietion Financial Institution treated by tlte IR.& as a 

N<>Di'atticipating·Financial Institution, then .the accOunt is not a U.S. 

~$b~e. A:~unt, b\rt.~~nt$ to t:P.eA~untHolder must be reported as 

~lated. in subpara8f8.Pll.l (b) of Article·4 oftheAgreement. 

3. hi all other cases, a Reporting Liechtenstein Financial Institution must 

olrtain:~·~lf.tCeJ:tifl¢ation .from the A~nnt.Holder.to ~liS'h the Account 

Hoi~'~. J~ .~oil t;h4.~lf;oeertifieation,,tJte)follOwillg rilles apply: , ' ' ' ' ' 

;,a) If:~,~~H~JdeJ:ii;sfJ,S~fleilQ.£)Peraon, the ~eporting Lieclttenstein Fin$1ota1I:nsti.tutionmust ~·the account as aU .s. 

Reportable Account. 

:b) . If theAceoun.t Hqlder is a.P~NFFE• the Reporting 

,LiCQh~.Finahcia,llnWfUtiqp.~:\)St .i~ti(y ~•Controlling 

Persons as detennined under AMLIKYC.Procedures, and must 

dc;tennine wh.ether any sucb person is a U.S .. citizen or resident on the 

basis ofa self ..certification from the A~t Holder or such person. If 

any such person is a U.S. citizen or resident, the Reporting 

Liecllwnstein Financial Institution must treat the account as a U.S. 

Reportable Account. 

c) If the Account Holder is: (i) a U~S. Person that is not a 

S~ified U.S. Person; (ii) subject to subparagraph B(3}(d) of this 

section, a Liechtenstein Financial Institution or other Partner 

Jurisdiction Financial Institution; (iii) a participating FFI, a deemedcompliant FFI, or an exempt beneficial owner, as those terms are 

defined in relevant U.S. Treasury Regulations; (iv) an Active NFFE; or 

(v) a Passive NFFE none of the Controlling Persons ofwhich is a U.S. 
citizen or resident, then the account is not a U.S. Reportable Account, 

and no reporting is required with respect to the account. 

d) IftheAccountHolder is a Nonparticipating Financial 

Institution (including a Uechtenstein Financial Institution or other 

Parmer Jurisdiction FinanCial Institution treated by the IRS as a 

Nonpartici~ing FinanCial. Institution), then the account is not a U.S. 

Reportable Accoutrt, but payments to· the Account Holder tnust be 

reported as contemplated in subparagraph I (b) of Article 4 ofthe 

Agreement. 

VI. Special Rules ahd Dei!liltions. ·The following additional rules and defmitions apply 

in implementing the due diligence procedures described above: 

A. Reliance on Self.;.€ertiftcations and Documentary Evidence. A Reporting 

Liechtenstein FinanCial Institution may not rely on a self-certification or documentary 

evidence if the Reporting Liechtenstein Financial Institution knows or has reason to 

know that the self-certifi~tion or documentary evidence is incorrect or unreliable. 

B. Definitions. The following definitions apply for purposes of this Annex I. 

1. A.MLfKVC Procedures. "AMUKYC Procedures" means the customer 

due diligence procedures of a Reporting Liechtenstein Financial Institution 

p'ursua.ht'to.the anti~oney laundering or similar requirements of 

Liedttenstein to Which sUch Reporting Liechtenstein Financial Institution 

is subject. 

2. NFFE. An ·~FE" means any Non·U.S. Entity that is not an FFI as 

deimetHn'relevantU;S. Treasury Regulations or is an Entity described in 

subparagraph B(4){j) ofthis section, and also includes any Non-U.S. 

Entity tbMis:establi~ed in Ueehtenstein or another Partner Jurisdiction 

·and that i~ not a Financial Institution. 

3. Passive NFFE. A "Passive NFFE" means any NFFE that is not (i) an 

Activt'NFPE;or (ii) a withholding foreign partnership or withholding 

foreign trust ptn'$uatlt to 'relevantU:S. Tteasury Regulations. 

4. Active NFFE. An .. Active NFFE .. means any NFFE that meets any of the 

followingmtetia: 

a) Less than· 50 percent of the NFFE?s. gross income for the preceding 

calendar year or other appropriate reporting period is passive 

income and less than 50 percent of the assets held by the NFFE 

during the preceding calendar year or other appropriate reporting 

period are assets that produce or are held for the production of 

passive income; 

b) The stock of the NFFE is regularly traded on an established 

securities market or the NFFE is a Related Entity of an Entity the 
stock ofwhich is regularly traded on an established securities 

t:narlcet; 

c) ~:.~f~j~;QI:g~d,in aU.~ .. T~tocy and all of the owners of 

thepayeeate~bona fide resfdentsofthatU.S. Territocy; 

d) TheNFFEisa,government (other than the U.S. government}, a 

pOlitical su'Qdiv.ision ofsuch government (which~ for the avoidance 

ofdoub~ includes a state, province, county, or municipality), or a 

public\botly performing a function of such government or a 

politictl! fiUbdivision thereof, a government of aU .S. Territory. an 

international organization~ ~non-U.S. central bank of issue, or an 

Entity- wholly 'Owned by one or more ofthe foregoing; 

e) Su~ally1\ll of the activities of the NFFE consist of holding (in 

whole or in part) the outstanding .stock of, or providing financing 

and servi~ to, one or more subsidiaries tha~ engage in trades or 

businesses ?Other than the business of a Financial Institution, except 

that.an entity shall not qualify for.this status if the entity functions 

{or holdsjtselfout}as an investment fund, such as a private equity 

fund~ venture capital fund, leveraged buyout fund, or any 

inveStment ~ehicle whose purpose is to: acquire or fund companies 

and~ hold interests in those companies as capital assets for 

investm~p~oses; 

f) ThecNFFS iScnoty.et operatin&:a. business and has no prior 

:Operati)lg:history i hJlt is investing:'Oapitatinto assets with the intent 

to operate $ business otherthan mat ofa Financial Institution, 

·prtWtdecJ:'ltbat tlle'NFFE sliallnot;q~fi,(Gt,tbis exception after the 

dat •. ibat;is l4months afterthe d•:ofthe initial organization of 

theNFFE; 

8} .. ~fNRPE~~aF~·~~~#le:.past five years, and 

is in tbe pi'ocess ¢liquidating its ~ o.r is. reorganizing with the 

,intentto~\te~,~·o~ons ina business other 

than tbat of'a.:J?inanoial fnstitudon; 

b) The NFFE,primlJrily engages in 'financing and hed~g transactions 

with, Dt fot,. R<CktedEntities that-are not Financial Institutions, and 

doesnotpnlvi4e,financing rhed~g services to any Entity that is 

not:aRelated Entity, proVided thatthe gtoup.of:any such Related 

Entities·~ primarily engaged in a business :other than that of a 

Financial Institution; 

i) The NFFE is.an "excepted NFFE" as described in relevant U.S. 

Treasury Regulations; or 

j) The NFFE meets aU of the following requirements: 

1. It is established and operated in itsjurisdiction of residence 

exclusively for religious, charitable, scientific, artistic, 
eultural, athletic, or educational purposes; or it is established 

and operated in its jurisdiction of residence and it is a 

prpfessional organizetion, business league, chamber of 

®nrinerce, labOr organization, agricultural or horticultural 

organization, civic league or an organization operated 

exclusively for the promotion of social welfare; 

it It is e~ernpt from ·income tax in its jurisdiction of residence; 

iii. It has no shareholders or members who have a proprietary or 

beneficial interest in its income or assets; 

iv. The applicable laws of the NFFE'sjurisdiction of residence 

or theNFFE's formation documents do not permit any 

income or assets ofthe NFFE to be distributed to, or applied 

for the 'benefit of, a private person or non-charitable Entity 

other than pursuant to the conduct of the NFFE's charitable 

activities, or as payment of reasonable compensation for 

services rendered, or as payment representing the fair market 

value of property which the NFFE has purchased; and 

v. The applicable laws of the NFFE's jurisdiction of residence 

ortheNPFE'sfonnation documents. require that, upon the 

NFFB's liquidation or dissolution, all of its assets be 

distributed to a governmental entity or other non-profit 

organization, or escheat to the government of the NFFE1 s 

jurisdiction of residence or any political subdivision thereof. 

5. PregistbJ:g Account ... A -'llreexisting.Aecaunt" means a Financial 

Account:maintain«i by aR~rting Financial Institution as of June 30, 

2014. 

C. AccountBalanqt.Aggm!atipn and ,eummey Trapslation Rules. 

l. At!f!l;egatiwtofftdi!iduaJ.Aceount§. For; purposes of determining 

the aggregate balanceorvalue,~fEimtncialAccountsheld by an individual, a 

Reporting Liech«mstein Financial Institution is required to aggregate all 

Financial Accounts maintained by the Rc;porting Liechtenstein Financial 

Institution, or by a Related EntitY; but'Ofi.tY to the extent that the Reporting 

Liechtenstmn Financial Institution's computerized systems link the Financial 

Accounts by reference,to a data element such as client number or taxpayer 

identification number, and,atlow account balances or values to be aggregated. 

Each holder of a jointly held Financial Account shall be attributed the entire 

balance or value of the jointly held Financial Account for purposes of applying 

the aggregation requirements described in this paragraph 1. 

2. Aggregation of Entity Accounts. For purposes of determining the 

aggregate balance or value of Financial Accounts held by an Entity, a 

Reporting Liechtenstein Financial Institution is required to take into account 

all Financial Accounts that are maintained by the Reporting Liechtenstein 

Financial Institution, or by a Related Entity, but only to the extent that the 
Reporting Liechtenstein Financial Institution's computerized systems link the 

FinanCial.~~ .l>Y teft;rel);OO.~qa 9~ta elelll~~t such as client nutril,)er or taxpayer~iaentiflcationmmiber~aa&allow B®Ount balances or values to be · ·.·. } .f .. ····· . ··. .... .. ...... .. .. . . . . . . . aggre~~,. 

3. . •• i\gvsmfio~ Bwe:A)lJ)licable:toltelationship .Managers. 

Forpurp0~~;~f::~c;tminin&lb~,Qiw.e~balan~-ervalue,¢Financlal 

Accounts:held:oy .. a peroo~ to:tletermin~w~ether .a Financial AcCQunt;is:a High 

Value Accp~~ aReppi1ing I.;iechtenstein Financial Institution is.also 

req~in the case ofany Financial Accounts that a relationship manager 

kno~$:. ot lt!l!J~ .~:1\IlOW, ~:;4ire,~~y ~or indirectly owned. ®ntrolled, or 

establishe,9(other than in ;:a fidu~ capacity) by thesame person, to 

aggregate ;all such,accounts. · 

4.. CurJ!lley Translaijgn Rule. For purposes of determining the balance 

or value ofFimm~al Accounts denominated in a currency other than the U.S. 

dollar, a Reporting Lieclltenstein Financial Institution must.convert the U.S. 

dollar thresl10ld, amoqots. descnl;x3~ in dlis A,nnex l int() such currency using a 

published spot rate·detetinin~ as of4te last day of the calendar year 

preceding.~ year in which ihe.Reporting Liechtenstein Financial Institution 

is detenninmg t!te ba181lce orMlJ,ue,. 

D. DocumerdaJX Evidence. Fot p-c;u.'p08e$ ofthis.Annex I, acceptable 

documentary evidenc.e includes any of the following: 

1. A certificate.of resid~ce i~ed .by an authorized government body 

(for examplef a .go-vernment or agency thereot: or· a municipality) of the 

jurisdiction in which ~e pay~.cl~ to be a resident. 

Z,. Wi~·~to.~.~diyi4tJal,any valld identification issued by~ 

authorized government boq (for'ex8Jllple, a government or agency thereof, or 

a xnuni~paJity). thab~lud.es ibe individual'~ naxne and is typical~y used for 

identificatiot;lpurposes. 

3. With ~to an E,ntityt a,ny o~al docum.entation issued by an 

authorized gov.erilment bodY.· {for example, a ·government or agen~y thereof, or 

a municipality) thatincludes the name of the Entity and either the address of 

its principal office in the juiisdj~oh {or U.S~ Tern tory) in which it ct~ms to 

be a resident or tbejUrlsdiotion .(or U.S. Territocy) in which the Entity was 

incorporated or organized. 

4. With~ tc:> a Financial Account maintained in ajurisdi~ion with 

anti~money laundering rules that have been ~proved by the IRS in connection 

with a QI agr~ment (as described in relevant U.S. Treasury Regulations). any 

of the documents, other than a Fonn W-8 or W-9, referenced in the 

jurisdiction's attachment to the QI agreement for identifying individuals or 

Entities. 

5. Any financial statement, third-party credit report, bankruptcy filing, or 

U.S. Securities and Exchange Commission report. 
E. Alternative Procedures for Financial :Accounts Held by Individual 

Beneficiaries of a Cash V:alutHn8uranee:t!ontntCt. A Reporting Liechtenstein 

Financial Institution ~Y ~e that an individual beneficiary (other than the 

owner) of a Cash Value Insurance Contract receiving a death benefit is not a Specified 

U.S. Person and may treat such FinancialAc:CQunl as,other, than a U.S. Reportable 

Account unless the Repottmg Liee1ttenstein Financial Instilution has actual 

knowledge, or reason to k.tiow; that the beneficiary is a 'Specified U :S. Person. A 

Reporting Liechtenstein Finaneial InstitutiQn has reason to know that a beneficiary of 

a Cash Value InsuranceContniot is a SpeCified U;S. Person if the information 

collected by the Reporting Liechtenstein Financial Institution and associated with the 

beneficiary contains U.S. indicia as described in subparagraph (B)(l) of section II of 

this Annex I. If a Reporting Liechtenstein Financial Institution has actual knowledge, 

or reason to know, that the beneficiary is a Specified U.S. Person, the Reporting 

Liechtenstein Financial Institution must follow the procedures in subparagraph B(3) 

of section II of this Annex I. 

F. Reliance on Third Parties. Regardless: of whether an election is made under 

paragraph C of section I of this Ahnex I, Liechtenstein may permit Reporting 

Liechtenstein Financial Institutions to rely on due diligence procedures performed by 

third parties, to the extent provided in relevant U;S. Treasury Regulations. 
Annexn 

I. Exempt Beneficial Owners other than Funds. Tb.e,JpUowing Entities shall be 

treated as Non-Reporting Liechtenstein Financial Institutions and as exempt beneficial 

owners for purposes ofsections 1411 andl47Z.ofthe U.S. Internal Revenue Code, 

other than wi~.~ ~() It pa.yi»~t ~bat.~ qerj.v~ ~Pl.~ obijMtion held in 

connection with acommereiaUmancial activitY.pfatf;pe el}:gaged in by a Specified 

Insurance Company. Cu$todial Institution. or Dep<)#ttjy. ~@tion. 

A.. Governwmtal.tllltiiv:..: .. J:b,Q: ~o:v~~tl1 ... ,,§.{ ,,q~ein, . 8l:lY political 

S\lbdivision of~:ti~~;{~~h; fo.x .th~?a~it18J:l.ce of ()Qubt; includes a state, 

province, . opunty; .. ~ munic1p;tlity),. or a~y .. , whoUy owned agency or 

instrumentalitY . of Li~.~ or aQY ane or· t:no.re of the foregoirig (each, a 

·~ieobt~Qov~"~). .~~~cr~~,i$::CQl1lP~·of~e·integral 

~, oon . tf-A .• 'ti . .. and ... litiCat:. ba•Vf'Si:::~.~u::.:::.:l: .... · ..' • . :IN~IGD.U .C($, . ,pG . $I I . .OJ.l$ . . .... c:,ull~ 

1. An inte,gRd~ of;U~~:a&l·~~;<:lll~Di~on":agency;t bureau. 

fund, instrUmentality, oro~ l*fy. boWe.ver deSignated,~ constit.Ute$.~ 

governing authority of'Liecbtenstein. The net eami~gs of the. governing authority 

must be ~to.lts.own ~QI'lt•.:orw~~·~ af~btenstein. With no 

portion inuring to the benefit ofany private person. An in~·~ does not 

include any individual who is a 'Sovereign, official, or administrator acting in· a 

private or personal capacity. · 

2. A controlled entity means an Entity that is separate in. form from Liechtenstein or 

that otherwise constitutes a separate juridical entity, provided that; 

a) The Entity is wholly owned:and controlled by. one or more Liechtenstein 

Governmental Entities directly or through one or more controlled entities; 

b) The Entity's net earnings are credited to its own account or to the accounts of 

one or more Liechtenstein Governmental Entities, with no portion of its 

income inuring to the benefit of any private person; and 
c) The Entity1

S assets vest in one or more Liechtenstein Governmental Entities 

upon dissolution. 

3. Income does 11ot inure to the benefit of private persons if such persons are the 

intended beneficiaries of a governmental program, and the program activities are 

performed for the general public with respect to thero~on welfare or relate to 

the administration of some phase ufgovemment. Notwithstanding the foregoing, 

however, income is considered to inure to the benefit "Of private persons if the 

income is derived from the use of a governmental entity io Conduct ·a commercial 

business, such as a commercial barildng business, that provides financial services 

to private persons; 

B. International Organization. Any internationat organization ·or wholly owned 

agency or instrumentality tllt::reof: This category includes any intergovernmental 

organization (including a supranational organization) (1) that is comprised 

primarily of non-U.S. governments; (2) that has in effect a headquarters 

agreement with Liechtenstein; and (3) the income of which does not inure to the 

benefit of private persons. 

C. Central Bank. The Swiss National Bank (Schweizerische Nationalbank) being 

the Liechtenstein Central Bank according to the Cl.lliency treaty between 

Liechtenstein and Switzerland of 19 June 1980 (Wtihrungsvertrag) and any of its 

wholly oWned subsidiaries; 

II. Funds that Qualify as ExemptBenefieial Ownen.:TH.e:.folloWilt8 Entities are 

·treated a:s Non-Repomng LiechtenstelntFmin\biaHnStitunods·and as: exempt beneficial 

owners for purposes of sections 1471 arid 1'4~ 'of the U~S. ]ntemal Revenue Code. 

A. Broad Parfieipation~R.etirement :Ftmd. A fund established in Liechtenstein to 

provide retirement. disability, ardeatbbenefits~ or anyoombination thereof, to 

beneficiaries that are current or former employees (or persons designated by such 

employees) of one or more employets:fn"oon$ld~tJn: fur seNices rendered, provided 

that the fund: · 

1. Does not have a single beneficiary with a right to more than five percent of the 

·fund's assets; 

2. Is subject to government regulation and provides annuaHnformation reporting 

about its beneficiaries to the relevant tax authorities in Liechtenstein; and 

3. Satisfies at .least one of the following requirements: 

a) The fund is generally exempt from tax in Liechtenstein on investment 

income under the laws of Liechtenstein due to its status as a retirement or 

pension plan; 

b) The fund receives at least 50 percent of its total contributions (other than 

transfers of assets from other plans described in paragraphs A through D of 

this section or from retirement and pension accounts described in subparagraph 

A( 1) of section V of this Annex II) from the sponsoring employers; 
c) Distributio,ns or withdrawal~ ff:qm:~y~ ar~.{ll1o~,qnty upon tpe 

~~ of8peci:fied.e:ven~ telatettto retirement, disability, ·or death (except 

rolloverdisttiblltionS;t<l·~thet\ .. • .· ~~.~beJI.io.~~ A 

through D of this ~tion orteti1em .. ;aJfd~911:~4.~~~ in 

subpaiagraph A(l) of section V of this Annex II)~ or penafties apply to 

distributi0l}S or withdrawals made be£ore,suc!l ~e,.d .e¥eit.f:s; pr 

d) Contributions {other than certain pet.mitted make-up CQntributions) by 

employees t0 the fund are li.tnit¢ by ~fere1;1ce to eap1ed income ofthe 

employee Dr may ..not exceed $.5.(4()00 ann.ually~"applying the roles set furth in 

Annex: I fur. a~unt·aggrega:tipn at)c:l o:&rency transla.tion,. 

B. Narrow Participation Retir-ement Fund.. Afimc:lesqlblished in Liechtenstein to 

provide retirement, ~s$ility~ or death benefits to benefipiarles that~ current or 

former employees (or persons designated by such employ~s) of one or mare 

employers in consideration for services rend~ provided that 

1. the fund has fewer than 50 participants; 

2 .. The fund is sponsor.ed .by one or more employers that~ no~ lp.v~ent Ep.tities or 

Passive NFFEs; 

3~ 14te employ~~ and etAPloY~ ~ntrW¢i9ns ~(), tqeJund (other than tranSfers of assets 

~IJ1 treaty-qualifiec:l·~.llmds ~cribedin~A.~t:*~~on or 

retirement and pension acco~ts described in subpanl.graph . .t\(n;qt;~¢Qtion J .of this 

Annex II) are limited by reference to earned illOOme and oompensation of the 

employee,. respectively; 

4 .. Pamoiponts'~~ao~~den~ otLk9htenst~in,~nslt·~·~m~~~ 2() 

~nt Qf~o fi.ln<l~.&;~l~<i 

~. The·fund.:.i$~su\:Jjeqt:tQ,~g0:~:~4im~4m:vi4$"tM•DPw;tl· jil(~on 

re~g~bout it$'~~£i~~~,tQ;·~&relevanu~x.· ~,in.,Lieclmmsteinc. Pension Fund .of·an Extmbt 'B!ntficiaiOJ!net<~A~-Sb,ed in . 

Liechtenstein by an exempt beneficial .owner to provide retirement, disability, or death 

benefitstobeneti¢~es ~~,participants tltata:re c~tW'Wt~ner ~ployees ofthe 

exempt benoticiat owner:(orpersoos.designate<i by .such.empJoy•), or that.-e not 

cutrent or foriner employ~, iftl¥dlenefits prqvidec:l ,tq(~~ ~efiqia[ies or 

participants .are in considemtion.Qf personal services performed for the;oxempt 

beneficial owner. 

D. Investment En#tr WhollY Owned by Exempt Beneficial Owners. An,Enticy 

that is a Liechtenstein Financial Institution solely because it is:an Investment Entity, 

provided that each direct holder of an Equity Interest in the Entity is an exempt beneficial 

owner, and each direct holder of a debt interest in such Entity is either a Depository 

lnstitution (with respectto a loan made to such Entity) or an exempt beneficial owner. 

Ill. Small or Limited Scope Financial Institutions that Quality as Deemed-Compliant 

FFis. The following Financial Institutions are Non-Reporting Liechtenstein Financial 
[nstitutions that shall be treated as deemed-compliant FFis for purposes of section 

1471 ofthe U.S. Internal Revenue Code. 

A. Ffuancial Institution with a LocalClient·Base. A Financial Institution satisfying 

the following requirements: 

1. The Financial Institution must be licensed and regulated as a financial institution 

under the laws of Liechtenstein; 

2. The Financial Institution must have no fixed place of business outside of 

Liechtenstein. For this purpose, a fixed place of business does not include a location 

that is not advertised to the public and from which the Financial Institution performs 

solely administrative support functions; 

3. The Financial Institution must not solicit customers or Account Holders outside 

Liechtenstein. For this purpose, a Financial Institution shall not be considered to have 

solicited customers or Account Holders outside Liechtenstein merely because the 

Financial Institution (a) operates a website, provided that the website does not 

specifically indicate that the Financial Institution provides Financial Accounts or 

services to nonresidents, and does not otherwise target or solicit U.S. customers or 

Account Holders, or (b) advertises in print media or on a radio or television station 

that is distributed or aired primarily within Liechtenstein but is also incidentally 

distributed or aired in other countries, provided that the advertisement does not 

specifically indicate that the Financial Institution proVides Financial Accounts or 

services to nonresidents, and does not otherwise target or solicit U.S. customers or 

Account Holders; 

4. The Financial Institution must be required under the laws of Liechtenstein to 

identify resident Account Holders for purposes of either information reporting or 

withholding of tax with respect to Financial Accounts held by residents or for 

purposes of satisfying Liechtenstein's AML due diligence requirements; 

5. At least 98 percent of the Fmaneial Ac.counts. by value maintained by the Financial 

Institution must be held by residents(inclndiitg residents that are Entities) of 

Liechtenstein or Switzerland or a Member State of the European Union or a Member 

State of the European Economic Area; 

6. Beginning on or before July 1, 2014, the Financial Institution must have .policies 

and procedures, consistent with those set forth in Annex I, to prevent the Financial 

Institution from providing a Financial Account tQ any Nonparticfpating Financial 

Institution and to monitor whether the Financial Institution opens or maintains a 

Financial Account for any Specified U.S. Person who is not a resident of 

Liechtenstein (including a U.S. Person that was a resident of Liechtenstein when the 

Financial Account was opened but subsequently ceases to be a resident of 

Liechtenstein) or any Passive NFFE with Controlling Persons who are U.S. residents 

or U.S. citizens who are not residents of Liechtenstein; 

7. Such policies and procedures must provide that ifany Financial Account held by a 

Specified U.S. Person who is not a resident of Liechtenstein or by a Passive NFFE 

with Controlling Persons who are U.S. residents or U.S. citizens who are not residents 
of Liepl>.~nsteig. ~ identifi~ the.FinaAcjal InsJit,ution ~report such Financial 

Acc~untas would be requiredif'the ~YtPI19i~ ~~~ W~.a ~ePQrtfu,g. . . Liecl'!teil$tein Fin~cial Institution (mQluding by fC;)Ilowing the applicable registration 

requirements. on the IRS FATCA regj$fiation ~bsite) or close such Financial 

Accotlnt; 

8. With respect to a PreexistingAccOuntheldby;ai'l.individllal who js not a resid~t of 

Liechtenstein or by an Entity~ the Financial In~tutiottm~;revic;.wt1rose,J:ireexisting 

Accounts in accOrdance with the procedures set forth. in Annex I app_licable to 

P~~ Accpw,us .to identify any U.S .. Rel)Qrt8bleAccount ot Financial Account 

held by a No~9ipating FinlltlciaJ ~tituti()ll, ap£t.m~xeport s\ltih Financial 

Account as would be required· if theFinanclal1nsti~OJ,l~-a~rting. 

Liechtenstein Financial Institution (inCluding by following the applicable registration 

requirements on the IRS FATCA registration website) 0r close ~ch Rinancial 

Account; 

9. Each Related Entity of the Financial Institution that is a Financial Institutiqn must 

be incorporated or organized in Liechtenstein and, with the exception of any Related 

J3J,l~ty that is a retirelllent fund described in paragraphs Atbrou~:D of;s.ecfion n of 

this Annex II, satisfy the requirements set forth in this paragraph A; and 

10. 'f4e Fina;n~al.lnsti,tution mll$1not have,w~oies or.practices that disctiminate 

against. opening or maint_a,.ii!Ing F~al Ac<;o~t$ f'o,r indiyid~s who ~Specified 

U.:S.JJ~ and ,.-esidents ofLiechtensteill.c 

B. Local Bank. A Financial Institution satisfying the foilowbrg requirements: 

I. TheFW,anciaf~~tution o~.sw~b',Ml~f!~~~:U~:~~~.~Wder~ laws o£~1~~nuts).(l{) :a bank or (b)_a~redit·umonor,sttnil&\eof:)petative credtt 

0 ~ · • DQO that~. • m->H+...it wi+kA.ut. rom•, . ..,:t&~M-.~ .~ P."'"'~· 

2 Th 1:7' ialT'ft.i+:futi . • bus' . • • adr f: ~· .. . de ~ c .4lo . . .. e.;,.,.~ , .• ~J'R~ ..... o~. s. . Jfl~.~f¥l~;P.mJJ. ~ ll!~ ~~: .. pas~ m 

and __.M-~ loans to . with t"'~ to a bankUnt:elated . .,.;.,.'Mn · ~em ... .r.A . 'th. .ui.QAJ.Uts ~ -.t'~· . . . . .. _, .... ~;P ... " ....... ,,. ··*•"" ~lL 

re$p00tto a creditunion or similar wc>~tive credit.orgamzatio~ members,. provided 

thatno;mCJl1Qethasa.~tetthPil five ~~Jp.~rest i,n~b;.~t~Qnor 

~peraiive,c;r~R~tion ; · · 

. . 

3. The Financial Institution satisfies the:requireJll.erlf:S~·~ fonh in ~plli'agraphs A{2) 

and A(3) ofthis section. provided that, in addition to the Umitatibns on fue.website 

described in subparagtaph A{3) of this section, the website does not pe.rmit the 

opening of a Financial Account; 

4. The Financial Institution does .not have more than $175 million in assets on its 

balance sheet, and the Financial Institution at1d any Related Entitiqs, taken together, 

do not have more than $500 million in total assets on their consolidated or combined 

balance sheets; and 

5. Any Related Entity must be incorporated or organized in Liechtenstein, and any 

Related Entity that is a Financial Institution, with the exception of any Related Entity 

that is a retirement fund described in paragraphs A through D of section II ofthis 
Annex II or a Financial Institution with only low-value accounts~described in 

patagraph C of this section, must satisfy the requirements set forth in this J»lfBgraph 

B. 

C. Financial Institution with Only Low-Value Accounts. A Liechtenstein Financial 

Institution satisfying the following requirements: 

1. The Financial Institution is not an Investment Eritity; 

2. No Financial Account maintained by the Financial Iruititution of at)y Related Entity 

has a balance dr value in excess of $50,000, applying the rules set forth in Annex I for 

account aggregation and currency translation; and 

3. The Financial Institution does not have more than $50 million in assets on its 

balance sheet, and the Financial Institution and any Related Entities, taken together, 

do not have more than $50 million in total assets on their consolidated or combined 

balance sheets. 

D. Qualified Credit Card Issuer. A Liechtenstein Financial Institution satisfying the 

following requirements: 

1. :The" Financial Institution is tt Financial Institution solely because it is an issuer of 

credit cards that aceepts deposits ·only when a c~omer make$ a payment in excess of 

a balance due with respect to the card and the overpayment ls not immediately 

returned to the customer; and 

2. Beginning on or before July 1, 2014, the Financial Institution implements policies 

and procedures to eillier prevent a customer deposit in excess Qf $50,000, or to ensure 

that any'customer deposit in excess of'$50,000, in each:ease·applying the rules set 

forth in Annex I for account aggregation and/currency translation, is refunded to the 

customer within 60 days. For this purpose, a custpmer deposit does not refer to credit 

balarices to the extent of dispUted 'charges but does include credit balances ~ting 

from merohartdise returns. 

IV. Investnlent,Entities1batQnalify as Deemed-Compliant FFis and Other Special 

Rules. The Financial Institutions described in paragraphS A through E ofthis 5ection 

are Non-Reporting Liechtenstein Financial Institutions that shall be treated as 

deemed.;oom:pliant FFis for,purposes of section 1471 oftheU.S. Internal Revenue 

Code. In addition, J»lfBgrapb F ofthis section provides Special rules applicable to an 

Investment Entity. 

A. Trustee-Documented Trust. A trust established under the laws of Liechtenstein to 

the extent that one of the trustees of the trust is a Reporting U.S. Financial Institution, 

Reporting Model 1 FFI, or Deemed Compliant FFI as defined in Section ITI (A) of this 

Annex Il that performs due diligence applicable to Reporting Liechtenstein Financial 

Institutions with respect to the Financial Accounts of the trust and follows the 

applicable registration requirements on the IRS FA TCA registration website if any 

information is required to be reported pursuant to the Agreement with respect to any 

account of the trust, or Participating FFI and reports all information required to be 
te})Orted pursuant to the Agteem~·with respecuo all:U.S. R.eportableAccounts of 

th~trust. 

B./Snot!§oredlnyestmentdmd!f.Ba~;JrorggD:£«lm~tAtion. A 

Financi81 InStitution des()ti~ m silbP8t;tgmph B(t) or 8(2) oftbis section having.a 

spo~ring entity'that compli~ with:lbe requkeUlents of)UQpar;lgt:aph .B(3) of this 

section. · 

1. A Financial fustitution is asponso~ inv:~ritentity if(a)'it1~ ~·lil~~ent Entityestaplish~ in Li~1lte11Stebt,·~ is nota qualified~ntermediary, withholding 

forei~ltpalin~or ~~~~.fo£Cign tqmtR~~~Qit{) re~~t Q.~. Tr~ 

Regulatlol)S;.~~)au:EJ)tity·haS'~ with the Financial, Institution to. act as a 

sponSoring entity for the Financial Institution. 

:2. AFinanci~ Institution is·a sponsored controlled foreign COl'pOration·if(a) the 

Fil.UUlcial Institution. is a controll<Xl foreign corporatiop. organized under the laws of 

U~ht~ 1ltat·isnot.aqualifiedintetmediary; withholdip.g foreign partnership, or 

withholding foreign trust pursuant to. rele~t U.s~ Treasuzy R.egqlations; (b 1 the 

F4natlcial Institution is wholly. owned, directly or ~directly, by a Reporting U.S. 

Financial Imtitution that agrees to act, or requires an affiliate of the Financial 

Institution to~~ 4SIJ91lSoting:entity for the Financla,llnstitf;ltion; and (c) the 

Financial Institution shares a common electronic account system vdth the:spo~g 

·entity that enable$ the $J>Onsoring entity to ideJl,tifY all Account Hqlders and payees of 

·' ~SinauciallnsijtuijoJI: IUld to acoess.all accoUnt and customet.infartnation 

.xnaitttain~ by the Fi~Ultl,cial Institution in~lvdHm,.b:ptnqtlinUtecl;to,;CU$0mer 

., ·idemlfiCitiM inf~o~ Cll$t<mt~r~en1lllion, .CCOunt'balance,..3nd ali 

paymentstnade to the Account Holder Gr payee. 

3. The sponsonns entity complies with the following requirements: 

a) The .spb~g entity is ~uthobd ~ aet·o~ bdlalfofthe. Financial 

Institutioni{Sltehault.fund manaser,·tJ;J;Ist~~ ciireeto~~ managing 

partnq')tQ, Mfill'·AAPlicable ~i9tl~eQ.tson·tli~ lRS FATCA 

registration website; 

·.b) llte spc>®tiu~·tmtitytw:registeredas a ~nsorlng:entity with theiRS on 

theiRS EATCA registration website; 

c) IfthespoliSOiingentity identifies an.y U.S. Reportable Accounts· with 

respect to the Financial Institution, the sponsoring entity registers the Financial 

Institution pursuant to applicable registration requirements :on the IRS FATCA 

registration website on or ~fore the lf,\ter :QfDecexp.ber 31, 2015 and the date 

that is 90 days after such aU .S. Reportable Aceount 1s first identified; 

d) The sponsoring entity agrees to perform, on behalf of the Financial 

Institution, all due diligence, withholding, reporting, and other requirements 

that the Financial Institution would have been required to perform if it were a 

Reporting. Liechtenstein Financial Institution; 
e) The sponsoring entity identifies the Financial Institution and includes the 

identifying numQet- ofthe Financial Institution (obtained by folloWing 

applicable registration requirements on the IRS F ATCA registration website) 

malftePorting:compl~on,'the Financial':Ih.stitution"s~;and 

f) The'SJ)Onsoring entity bas not had its status as a sponsor revoked. 

C. Sponsored, Closely Held Investment Vehicle. A Liechtenstein Financial 

Institution satisfyfug the ftjlloWillg requirementS: 

1. The Financial Institution is a Financial Ih.stitution solely because itis an Investment 

Entity and is,not a qualifiedJntetmediary, Withholding foreign partnership. or 

withllolding' foreign truSt pUrsUant ro relevant U :S. Treasury Regulations; 

2. The sponsoring entity is a Reporting U.S. Financial Institution, Reporting Modell 

FFI, or Participating FFI, is authorized to act on behalf of the Financial Ih.stitution 

(such as a professional manager, trustee, or managing partner), and agrees to perform, 

on behalf of the Financial Institution, all due diligence, withholding, reporting, and 

other requirementS that the Financial Institution would have been required to perfoun 

if it were a Reporting Liechtenstein Financial Institution; 

3. The Financial Institution does not hold itself out as an investment vehide for 

unrelated parties; 

4. Twentytlr fewer individuals'own all of the debt interests and 'Equity Interests in the 

Fin8lleiallnstitution (disregarding-debt interests owned by Partiei~ Ffls,and 

deemed-cotilpliMt FFis11tld tk{uitylnterests ,owned by an Entity if,that Entity owns 

100 pertent of the Equity Interests in the Financial Institution and is itselfa-sponsored 

Financial Tn$titution described in this paragraph C); and 

5. The sponsoring entity complies with the following requirements: 

a~' The sponsoringenti1y has, registered as a sponsoring entity with the IRS on 

the IRS F A:T<M. registration website; 

b) The sponsoring entity agrees to. perform, on behalf of the Financial 

Institution, all:due,diligence, withholding, reporting, ~and othenequirements 

that the Financial Institution would have been required to perform if it were a 

Reporting Liechtenstein Financial Institution and retains documentation 

colleeted With respeCt to the·Financial Institution for a period· of six years; 

c) The sponsoring entity.identifies the Financial Institution in all reporting 

completed on the Financial Institution's behalf; and 

d) The sponsoring entity has not had its status as a sponsor revoked. 

D. Investment Advisors and Investment Managers. An Investment Entity, 

including Investment Entities established in Liechtenstein and regulated by the 

Liechtenstein Financial Markets Authority (FMA} according to the Law on Asset 

Management of 25 November 2005, established in Liechtenstein that is a Financial 

Institution solely because it (1) renders investment advice to, and acts on behalf of, or 
(2) ~es IJ9rtfolios for. and. acts on behalf of, a customer for the purposes of 

investin& ~·'or admi.Qis~g fupds.~posited in tlte nanxe ofthe customer 

:with .Q..PinaDcihllnstitution other ~A Nonparticipating FinanciaUnstitution. - . . . . .. . - . . 

E. cnn~e~fD-egfYehicle. :AnJnveStment En~ityestabiiShed.in. Liechtenstein 

thatjs.regw&.t¢d as a collective inves1;mentve4icle, provid,ed that all·ofthe interests in 

tbc;~.,.conepti~e.investment Ydilcle (includfug.d¢bt lfiterests ·¥1 .. exc~ of $50,000) are 

hel<{·h~ .~t.W9~gb ~e .or more ~empt be11eficial o.wners. Active NFFEs described in 

subparagrapnB(4) of section VI of A.nnex I. u.s. Persons tlult.are not Specified U.S. 

Persons, or Financial Institutions that are not Nonparticipating Financial Institutions. 

F. SpedalRules~.J'he following rules.apply to anlnvestment Entity: 

1. With respect to interests in an Investment Entity that is a collective investment 

vehicle des.cribed in. paragraph E of this section, the reiJ9rting obligations of any 

Investment Entity (other than a Financial Institution through which interests in the 

e;pl~~h~e inv~tment vehicle are. held) shall be deemed fulfilled. 

2: · )Vlth respecrto interests in: 

a) Alllnv~ent Entity .established in a Partner Jurisdiction tl.lat is. ~wated 

.as ~·.~~Y~inyestmMt vdUcle,.all Qf;the interests in which {including debt 

int~~ ~~s of.$50,00()}·~ held.by or .Un'ou,gh.ol\e.o,r.IIlAre~empt 

beneficial owners, Active NFFEs described in subpai-agraphB(4J of Section VI 

of Annex I. u.s. Persons that are not Specified u.s. Persons, or Financial 

~~~that.are.Jlot Nonparticipating,Fmancia1 Institutions;,or 

b) Ali Ihve5tment Entity that is a qualified co1lectiye jn~~ vehiole under 

rel~v.ant U.S. Treasury Regulations; 

':the ~'obligations of any Ihvestment Entity that is a,Liechtensrem F,imm~ ~tu.tion (othei than a Financia11hstitution through whidl.interests .Pttb.ecpl!~Y:e:inves~eat vehicle.~beld),$all:~ d,~'fulfified. 

:Lwit&~~'-sts.lttau.lnYe&tplent Imli.ty ~~b~<Lin Li~~stein that is 

qat ~~Jni~h.n orsu~F(l}o:fithis ~~.consiStent with 

paragraph 3 of Article 5 of the Agreement, the reporting ohligariollS of all other 

Investment Entities with respect to such interests shall be deemed fulfilled ifthe 

inf~on~~ to be rc;potted.l;ly the.~-:-mentioned Investment Entity pursuant 

to theA.~, with respect to such interests is reported by such Investment Entity 

or another person. 

4. An Investment Entity established in Liechtenstein that is regulated as a collective 

investment vehicle shall not fail to qualify under paragraph E or subparagraph 0(2) of 

this section. or otherwise as a deerned.,.compliant FFI, solely because the collective 

investment vehicle has issued physical shares in bearer form, provided that: 

a) The collective investment vehicle has not issued, and does not issue, any 

physical shares in bearer form after Decel;Ilber 31, 201 2; 

b) The collective investment vehicle retires all such shares upon surrender; 
c) The ~olle<ftj_ve in~~nt v~~cle( or a RepOrting Liechtc:nstein .Financial 

Ill$d:tuticm),penonns the due diligence procedures set forth m Annex I and 

report'S any information required to be reported with respect to any such shares 

when·suCh SltareS arepre8enteit'for redemption or other payment; and 

d} The:oollecti"e·inveStm.ent vehicle has ih place policies and procedqres to 

ensundluitsuch Share.Sareredeemed oriinmobilized as soon as possible, and 

in MY event priorto 'January t. 2017. 

V. Account§ Excluded from Financial Accounts. The following accounts are. excluded 

from the definition ofFinancial·Accounts and therefore shall not be treated as U.S. 

Reportable Accounts. 

A. Certain Savings Accounts. 

1. Personal Retirement Accounts & Insurance Premiums for Retirement. Accounts 

and insurance contracts established with the purpose of receiving, managing and 

saving resources for occupational and private pension plans covered by article 1 of the 

Law on Occupational Benefits of2Q October 1987 (Gesetz fiber die Betriebliche 

Personalvorsorge BPVO), article 1 of the Law on the Supervision on Institutions on 

Occupational Benefitsc0f24 November 2006 (Oesetz betreffend die Aufsicht Uber 

Einrichfungen der>betiieblic,hen Personalvorsorge PFG) or similar laws of Partner 

Jurisdictions; 

2. Non-'Retitement Savings·Aooaunts. :An 'aodount maintained in Liechtenstein (other 

than an !nsura~JC(}or Annuity Contract) that satisfies the following requirements under 

the taws ofLieoli~. 

a) The account is subject to regulation as a savings vehicle for pqrposes other 

than fot retirement; 

b) The aecoumis.mx-tavored (f.'e., coritributions to the accOunt that would 

otherwise be subjectto tax under the laws of Liechtenstein are deductible or 

exolud~ frtJm the gi'oss ipCQ!ne or"tbe accoijnt holder or taxed at a reduced 

rate, ortmfatitfu"ofmvesttnentincomefi'otn the accbuntis deferredormxed at 

a reduced Tate); 

c) Withdrawals are conditioned on meeting specific criteria related to the 

pqrpose of the 'S&.Vings account (for example, the provision of educational or 

medical benefitS). or penalties apply to withdrawals made before such criteria 

are met; and 

d) Annual contnoutions are limited to $50,000 or less, applying the rules set 

forth in Annex I for account aggregation and currency translation. 

B. Certain Term Life Insurance Contracts. A life insurance contract maintained in 

Liechtenstein with a coverage period that will end before the insured individual attains 

age 90, provided that the contract satisfies the following requirements: 
l. Pe.Qocli~.PtenU,~. ~~;~<>,not d~oyer time~ are pa~ble at least annually 

dlll'ing:the;penOdthe oohti'#t 'is in exi~~~ or until the insu.rc;:d attaip.s age 90, 

whichevef:is shorter; 

2. The ccmtmct ~tasno.®ntr~t:val~e th~·MY person can ~ooe.ss {qy withdrawal, loan, 

or ·ofuerWi~) Wftiioiit ten;rilruiting the conhUct; 

~· Th~ amoWJ-t{ o~ert4an a:~ ·benefit)pa~le upo11.'C8llcellationl>rt~on of 

the•e<)ntract~ote;,ce¢~dJh~ &ggregatep~~ums paid for the contract, less the sum 

of:mortaliijr,morbidity~:and ~nse chaige8 (whether or not actually imposed) for the 

peri ad orperiodS.c>ftlie ~n~~t·~ ~istenee Md ~Y amounts paid prior to the 

cancetladon or'terhlinatiolt(lftlie eonttact; antl 

4. Theconttacrisn:otbeld by atransferee for value. 

C. Account Held. By an Estate. An ~unt maintaine<l in Liechtenstein that is held 

solefy by ari'eSta.teifthe documentation for such account includes a copy of the 

deceased's will or death cet;tifieate. 

D. Escrow t\!;qo:untS.An.~unt maintained in Liechtenstein established in 

connection with' any of tile f9Uowing: 

L A eourt order or lid . ent . . ,... ,. ' . . / J. ' ~ ,, ., 

. . . 

2. A.sal~, ~~~&e,.,Q:rl~e·oftea! orper:son.alproperty:, .provided that:theaccount 

satiSfies the'fb1IOW!ijg req~~tz;: · · 

~)111~·~\!Jll~ ~4e4S9lelywi~ a4\)~llP;a)'lllent eamestmon~, d~sit .in~$( · ·· 1 g~Df'- to secure an bli anon c:Jiredtl .rel. ated to the ... ,, .. ~~ ...... .......,.. ....... .().,8 ...... · ..... Y .•.. ,. ,. . ,, ' ~·6t~il . i1 . . . . eii(ml fhnded.wifb a financial assetthat is *-

~;· 'an'm~~:=:f'ilitrixiec&!·With tb.e ~ exchail · 6t1 v .of the ·' ,. ,. .· ., .,., .•. ··.·, ........ &~ .•.. ~ . 

b)~~'•· Jj~ ~~lu~iand ~S<?lely to~ .theol>Iis~911 of the ..o~ll.so. ... r;tb' ~ ··~J. .. ;c..;.; · ·ce.rodn~ . · the seller to. · • · ,1:'""~·~··· ,., .P.!-Y~J@'l. ,., .. ,.,A,,p~, .. ·. ··. pay$J.y 

~9j :;· . ~,brihe lessor or.1~,1o~ for&tY ~relating to 

the leas~ PI:Operty a,s agreed under the lease; 

c) The a,s~ts ~fthe accollJlt. in~ludit}g,the income earned thereon. will be paid 

or oth~ clistrll;Jute<;l for the. benef.i~:~fthe pprch~, seller, lessor~ or lessee 

(inclUding to satisfy such person ~s abUg~on)when the property is sold, 

exchange(J, or surrendered, or the lease terminates; 

d) The .acc()unt .is 1\0t a margin or similpr account established in connection 

with a sale or exchange of a fmancial as5et; and 

e) The account is not associated with a credit card account 
3. An obligation nfa Fimmpial Institution servi.ciJ:m .a lo.an secured by teal·ptQperty to 

set aside aportionofapa)'lllent solety·to faciHtate the payptent oftaxes or insurance 

related to the real property at a later time. 

4. An obligation of a Fin1lllclal Institution solely to facilita~ the payptent of taxes at a 

later time. 

E. Partner Jnrisdictlon AccountS. An account maintained in Liechtenstein and 

exeluded from the definition ofFinancial Apcount under an agreement between the 

Unit$! States·and another Partner Jutisdietionto faCilitate th~ iptplementation of 

F ATCA, provided that such aCcount is subject to ·the same requirements and oversight 

under the laws ofsuch other Partri.er JUriSdiction as if sueh account were established in 

that Partner Jurisdiction and maintained by a Partner Jurisdiction Financial Institution 

in that Partner Jurisdiction. 

VI. Definitions. The following additional definitions apply to the descriptions above: 

A. Reporting Model 1 FFI. The term "Reporting Model 1 FFI" means a Financial 

Institution with respect to which a non-U.S. government or agency thereof agrees to 

obtain and exchange information pursuant to a. Model 1 IGA, other than a Financial 

Institution treated as a Nonparticipating Financial fnstitution under the Model l IGA. 

For purposes of this definition, the term "Model I IGA" means an arrangement 

between the United States or the Treasury Department and a non-U.S. government or 

one or more agencies thereof to implement FA TCA through reporting by Financial 

Institutions to such. non'-U.S;'go~'ent·orage~~thereOf, followed by automatic 

exchange of such reported infotma.tion with the lRS. 

B. Participating FFI. Th~ tenn "Participating FFI" means a Financial Institution that 

has 'agteed'to complywith'fhe f~~tS Of an FFI. Agreenj~t, Uicluding a 

Financial Institution d.escrib$l m aM0de12 101\that has a~eed tO. comply with the 

requitetnel1ts of1m FFI Agreematt~'The term Participating FFI alSQ ~tudes a 

qualified intermediary branch ofa R~rting U.S. Financial Institutl6n, unless such 

branch is a Reporting Model) FP{. For putp<)S.es ofthis. defu:litio~ •. tbe term FFI 

Agreement means an agreement~ setS ~rt&lh~ requirements for a Financial 

Instifu.tion ~.be tt'$te<fl\S eorijpl~i'Yii:lithe requirem~~ofsection 147I(b) of the 

u~s. Intemal Revenuecoae.ltriclditit:)tt;tOr purposes ofthis d~firutio~ the term 

Model2 IGA means an arrartgement between the United States or the Treasury 

Department and a non~U.S. gov~entor one or.mC)re agencies thereof to facilitate 

the ifnplementatiori:ofFATCAil1rOughtepotting by Fmancial Institutions directly to 

the IRS in accord8llce·with the reqlJirements of an FFI Agreement, supplemented by 

the exchange of information betWeen such non-U.S. government or agency thereof 

and the IRS. 

C. Trost. The term "Trust" shall include trusts, foundations and non-commercial 

establishments ("Anstalten") if the foundation. or establishment is created for the 

primary purpose of protecting or conserving the property of the foundation or 

establishment on behalf of beneficiaries. The term "trustee" shall include the members 

ofthe Foundation Board and the Board of Directors acting on behalf of a 

Liechtenstein foundation or establishment.