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Agreement Between the United States of America and the Kingdom of 

Spain to Improve International Tax Compliance and to Implement FATCA

Whereas, the United States of America and the Kingdom of Spain (each, a 

“Party”) have a longstanding and close relationship with respect to mutual 

assistance in tax matters and desire to conclude an agreement to improve 

international tax compliance by further building on that relationship,

Whereas, Article 27 of the Convention between the United States of America 

and the Kingdom of Spain for the Avoidance of Double Taxation and the 

Prevention of Fiscal Evasion with Respect to Taxes on Income and its Protocol, 

done at Madrid on February 22, 1990, (“the Convention”) authorizes exchange 

of information for tax purposes, including on an automatic basis,

Whereas, the United States of America enacted provisions commonly known as 

the Foreign Account Tax Compliance Act (“FATCA”), which introduce a 

reporting regime for financial institutions with respect to certain accounts,

Whereas, the Kingdom of Spain is supportive of the underlying policy goal of 

FATCA to improve tax compliance,

Whereas, FATCA has raised a number of issues, including that Spanish financial 

institutions may not be able to comply with certain aspects of FATCA due to 

domestic legal impediments, 

Whereas, the United States of America collects information regarding certain 

accounts maintained by U.S. financial institutions held by residents of Spain 

and is committed to exchanging such information with the Kingdom of Spain 

and pursuing equivalent levels of exchange,

Whereas, the Parties are committed to working together over the longer term 

towards achieving common reporting and due diligence standards for financial 

institutions,

Whereas, the United States of America acknowledges the need to coordinate the 

reporting obligations under FATCA with other U.S. tax reporting obligations of 

Spanish financial institutions to avoid duplicative reporting,

Whereas, an intergovernmental approach to FATCA implementation would 

address legal impediments and reduce burdens for Spanish financial institutions,

Whereas, the Parties desire to conclude an agreement to improve international 
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tax compliance and provide for the implementation of FATCA based on 

domestic reporting and reciprocal automatic exchange pursuant to the 

Convention and subject to the confidentiality and other protections provided for 

therein, including the provisions limiting the use of the information exchanged 

under the Convention.

Now, therefore, the Parties have agreed as follows:

Article 1

Definitions

1. For purposes of this agreement and any annexes thereto (“Agreement”), 

the following terms shall have the meanings set forth below:

a) The term “United States” means the United States of America, 

including the States thereof, and, when used in a geographical 

sense, means the territory of the United States of America, 

including inland waters, the air space, the territorial sea thereof and 

any maritime area beyond the territorial sea within which the 

United States may exercise sovereign rights or jurisdiction in 

accordance with international law; the term, however, does not 

include the U.S. Territories. Any reference to a “State” of the 

United States includes the District of Columbia. 

b) The term “U.S. Territory” means American Samoa, the 

Commonwealth of the Northern Mariana Islands, Guam, the 

Commonwealth of Puerto Rico, or the U.S. Virgin Islands.

c) The term “IRS” means the U.S. Internal Revenue Service.

d) The term “Spain” means the Kingdom of Spain and, when used in 

a geographical sense, means the territory of the Kingdom of Spain, 

including inland waters, the air space, the territorial sea and any 

maritime area outside the territorial sea upon which, in accordance 

with international law and on application of its domestic 

legislation, the Kingdom of Spain exercises or may exercise in the 

future jurisdiction or sovereign rights with respect to the seabed, its 

subsoil and superjacent waters, and their natural resources.

e) The term “Partner Jurisdiction” means a jurisdiction that has in 

effect an agreement with the United States to facilitate the 

implementation of FATCA. The IRS shall publish a list identifying 

all Partner Jurisdictions.

f) The term “Competent Authority” means:
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(1) in the case of the United States, the Secretary of the Treasury 

or his delegate; and

(2) in the case of Spain, the Minister of Finance and Public 

Administrations or his authorized representative.

g) The term “Financial Institution” means a Custodial Institution, a 

Depository Institution, an Investment Entity, or a Specified 

Insurance Company.

h) The term “Custodial Institution” means any entity that holds, as a 

substantial portion of its business, financial assets for the account 

of others. An entity holds financial assets for the account of others 

as a substantial portion of its business if the entity’s gross income 

attributable to the holding of financial assets and related financial 

services 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 determination is being made; 

or (ii) the period during which the entity has been in existence.

i) The term “Depository Institution” means any entity that accepts 

deposits in the ordinary course of a banking or similar business. 

j) The term “Investment Entity” means any entity that conducts 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:

(1) trading in money market instruments (cheques, bills, 

certificates of deposit, derivatives, etc.); foreign exchange; 

exchange, interest rate and index instruments; transferable 

securities; or commodity futures trading;

(2) individual and collective portfolio management; or

(3) otherwise investing, administering, or managing funds or 

money on behalf of other persons.

This subparagraph 1(j) shall be interpreted in a manner consistent 

with similar language set forth in the definition of “financial 

institution” in the Financial Action Task Force Recommendations.

k) The term “Specified Insurance Company” means any entity that 

is an insurance company (or the holding company of an insurance 
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company) that issues, or is obligated to make payments with 

respect to, a Cash Value Insurance Contract or an Annuity Contract.

l) The term “Spanish Financial Institution” means (i) any Financial 

Institution resident in Spain, but excluding any branches of such 

Financial Institution that are located outside Spain, and (ii) any 

branch of a Financial Institution not resident in Spain, if such 

branch is located in Spain.

m) The term “Partner Jurisdiction Financial Institution” means (i) 

any Financial Institution resident in a Partner Jurisdiction, but

excluding any branches of such Financial Institution that are 

located outside the Partner Jurisdiction, and (ii) any branch of a 

Financial Institution not resident in the Partner Jurisdiction, if such 

branch is located in the Partner Jurisdiction.

n) The term “Reporting Financial Institution” means a Reporting 

Spanish Financial Institution or a Reporting U.S. Financial 

Institution, as the context requires.

o) The term “Reporting Spanish Financial Institution” means any 

Spanish Financial Institution that is not a Non-Reporting Spanish 

Financial Institution.

p) The term “Reporting U.S. Financial Institution” means (i) any 

Financial Institution that is resident in the United States, but 

excluding any branches of such Financial Institution that are 

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 information is required to be exchanged under subparagraph 

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

q) The term “Non-Reporting Spanish Financial Institution” means 

any Spanish Financial Institution, or other entity resident in Spain 

that is identified in Annex II as a Non-Reporting Spanish Financial 

Institution or that otherwise qualifies as a deemed-compliant FFI, 

an exempt beneficial owner, or an excepted FFI 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 Spanish Financial 

Institution or other Partner Jurisdiction Financial Institution other 
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than a Financial Institution identified as a Nonparticipating 

Financial Institution pursuant to paragraph 2 of Article 5.

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

Financial Institution, and includes:

(1) in the case of an entity that is a Financial Institution solely 

because it is an Investment Entity, any equity or debt interest 

(other than interests that are regularly traded on an 

established securities market) in the Financial Institution;

(2) in the case of a Financial Institution not described in 

subparagraph 1(s)(1) above, any equity or debt interest in the 

Financial Institution (other than interests that are regularly 

traded on an established securities market), if (i) the value 

of the debt or equity interest is determined, directly or 

indirectly, primarily by reference to assets that give rise to 

U.S. Source Withholdable Payments, and (ii) the class of 

interests was established with a purpose of avoiding 

reporting in accordance with this Agreement; and

(3) any Cash Value Insurance Contract and any Annuity 

Contract issued or maintained by a Financial Institution, 

other than a noninvestment-linked, nontransferable 

immediate life annuity that is issued to an individual and 

monetizes a pension or disability benefit provided under an 

account, product, or arrangement identified as 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 identified as 

excluded from the definition of Financial Account in Annex II.

t) The term “Depository 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.

u) The term “Custodial Account” means an account (other than an 

Insurance Contract or Annuity Contract) for the benefit of another 
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person that holds any financial instrument or contract held for 

investment (including, but not limited to, a share or stock in a 

corporation, a note, bond, debenture, or other evidence of 

indebtedness, a currency or commodity transaction, a credit default 

swap, a swap based upon a nonfinancial index, a notional principal 

contract, an Insurance Contract or Annuity Contract, and any 

option or other derivative instrument).

v) The term “Equity Interest” means, in the case of a partnership 

that is a Financial Institution, either a capital or profits interest in 

the partnership. In the case of a trust that is a Financial Institution, 

an Equity Interest is considered to be held by any person treated as 

a settlor or beneficiary of all or a portion of the trust, or any other 

natural person exercising ultimate effective control over the trust. 

A Specified U.S. Person shall be treated as being a beneficiary of a 

foreign trust if such Specified U.S. Person has the right to receive 

directly or indirectly (for example, through a nominee) a 

mandatory distribution or may receive, directly or indirectly, a 

discretionary distribution from the trust. 

w) The term “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.

x) The term “Annuity Contract” means a contract under which the 

issuer agrees to make payments for a period of time determined 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 Insurance Contract” means an Insurance 

Contract (other than an indemnity reinsurance contract between 

two insurance companies) that has a Cash Value greater than 

$50,000.

z) The term “Cash Value” means the greater of (i) the amount that 

the policyholder is entitled 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 
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foregoing, the term “Cash Value” does not include an amount 

payable under an Insurance Contract as: 

(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 previously paid premium 

under an Insurance Contract (other than under a life 

insurance contract) due to policy cancellation or termination, 

decrease in risk exposure during the effective period of the 

Insurance Contract, or arising from a redetermination of the 

premium due to correction of posting or other similar error; 

or 

(3) a policyholder dividend based upon the underwriting 

experience of the contract or group involved.

aa) The term “Preexisting Account” means a Financial Account 

maintained by a Reporting Financial Institution as of December 31, 

2013.

bb) The term “Reportable Account” means a U.S. Reportable 

Account or a Spanish Reportable Account, as the context requires.

cc) The term “Spanish Reportable Account” means a Financial 

Account maintained by a Reporting U.S. Financial Institution if: 

(i) in the case of a Depository Account, the account is held by an 

individual resident in Spain and more than $10 of interest is paid to 

such account in any given calendar year; or (ii) in the case of a 

Financial Account other than a Depository Account, the Account 

Holder is a resident of Spain, including entities that certify that 

they are resident in Spain for tax purposes, with respect to which 

U.S. source income that is subject to reporting under chapter 3 or 

chapter 61 of subtitle A of the U.S. Internal Revenue Code is paid

or credited.

dd) The term “U.S. Reportable Account” means a Financial Account 

maintained by a Reporting Spanish 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.
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ee) The term “Account Holder” means the person listed or identified 

as the holder of a Financial Account by the Financial Institution 

that maintains the account. A person, other than a Financial 

Institution, holding a Financial Account for the benefit or account 

of another person as agent, custodian, nominee, signatory, 

investment advisor, or intermediary, is not treated as holding the 

account for purposes of this Agreement, and such other person is 

treated as holding the account. In the case of a Cash Value 

Insurance Contract or an Annuity Contract, the Account Holder is 

any person entitled to access the Cash Value or change the 

beneficiary of the contract. If no person can access the Cash Value 

or change the beneficiary, the Account Holders are any person 

named as the owner in the contract and any person with a vested 

entitlement to payment under the terms of the contract. Upon the 

maturity of a Cash Value Insurance Contract or an Annuity 

Contract, each person entitled to receive a payment under the 

contract is treated as an Account Holder.

ff) The term “U.S. Person” means a U.S. citizen or resident 

individual, a partnership or corporation organized in the United 

States or under the laws of the United States or any State thereof, a 

trust if (i) a court within the United States would have authority 

under applicable law to render orders or judgments concerning 

substantially all issues regarding administration of the trust, and (ii) 

one or more U.S. persons have the authority to control all 

substantial decisions of the trust, or an estate of a decedent that is a 

citizen or resident of the United States. This subparagraph 1(ff) 

shall be interpreted in accordance with the U.S. Internal Revenue 

Code.

gg) The term “Specified U.S. Person” means a U.S. Person, other 

than: (i) a corporation the stock of which is regularly traded on one 

or more established securities markets; (ii) any corporation that is a 

member of the same expanded affiliated group, as defined in 

section 1471(e)(2) of the U.S. Internal Revenue Code, as a 

corporation described in clause (i); (iii) the United States or any 

wholly owned agency or instrumentality thereof; (iv) any State of 

the United States, any U.S. Territory, any political subdivision of 

any of the foregoing, or any wholly owned agency or 

instrumentality of any one or more of the foregoing; (v) any 

organization exempt from taxation under section 501(a) or an 

individual retirement plan as defined in section 7701(a)(37) of the 

U.S. Internal Revenue Code; (vi) any bank as defined in section 
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581 of the U.S. Internal Revenue Code; (vii) any real estate 

investment trust as defined in section 856 of the U.S. Internal 

Revenue Code; (viii) any regulated investment company as defined 

in section 851 of the U.S. Internal Revenue Code or any entity 

registered with the Securities Exchange Commission under the 

Investment Company Act of 1940 (15 U.S.C. 80a-64); (ix) any 

common trust fund as defined in section 584(a) of the U.S. Internal 

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)(1) 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; or (xii) a broker as defined in section 6045(c) 

of the U.S. Internal Revenue Code. 

hh) The term “Entity” means a legal person or a legal arrangement 

such as a trust. 

ii) The term “Non-U.S. Entity” means an Entity that is not a U.S. 

Person.

jj) The term “U.S. Source Withholdable Payment” means any 

payment of interest (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. Source Withholdable 

Payment does not include any payment that is not treated as a 

withholdable payment in relevant U.S. Treasury Regulations.

kk) 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 direct or indirect 

ownership of more than 50 percent of the vote or value in an 

Entity. Notwithstanding the foregoing, Spain may treat an Entity 

as not a Related Entity of another Entity if the two Entities are not 

members of the same expanded affiliated group as defined in 

section 1471(e)(2) of the U.S. Internal Revenue Code.

ll) The term “U.S. TIN” means a U.S. federal taxpayer identifying 

number.
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mm) The term “Spanish TIN” means a Spanish taxpayer identifying 

number. 

nn) The term “Controlling Persons” means the natural persons who 

exercise control over an entity. In the case of a trust, such term 

means the settlor, the trustees, the protector (if any), the 

beneficiaries or class of beneficiaries, and any other natural person 

exercising ultimate effective control over the trust, and in the case 

of a legal arrangement other than a trust, such term means persons 

in equivalent or similar positions. The term “Controlling Persons” 

shall be interpreted in a manner consistent with the 

Recommendations of the Financial Action Task Force.

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 of the Party applying the 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.

Article 2

Obligations to Obtain and Exchange Information with Respect to 

Reportable Accounts

1. Subject to the provisions of Article 3, each Party shall obtain the 

information specified in paragraph 2 of this Article with respect to all 

Reportable Accounts and shall annually exchange this information with the 

other Party on an automatic basis pursuant to the provisions of Article 27 of the 

Convention.

2. The information to be obtained and exchanged is:

a) In the case of Spain with respect to each U.S. Reportable Account 

of each Reporting Spanish Financial Institution:

(1) the name, address, and U.S. TIN of each Specified U.S. 

Person that is an Account Holder of such account and, in the 

case of a Non-U.S. Entity that, after application of the due 

diligence procedures set forth in Annex I, is identified as 

having one or more Controlling Persons that is a Specified 

U.S. Person, the name, address, and U.S. TIN (if any) of 

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

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

(3) the name and identifying number of the Reporting Spanish 

Financial Institution;

(4) the account balance or value (including, in the case of a Cash 

Value Insurance Contract or Annuity Contract, the Cash 

Value or surrender value) as of the end of the relevant 

calendar year or other appropriate reporting period or, if the 

account was closed during such year, immediately before 

closure; 

(5) in the case of any Custodial Account: 

(A) the total gross amount of interest, the total gross 

amount of dividends, and the total gross amount of 

other income generated with respect to the assets held 

in the account, in each case paid or credited to the 

account (or with respect to the account) during the 

calendar year or other appropriate reporting period; 

and 

(B) the total gross proceeds from the sale or redemption of 

property paid or credited to the account during the 

calendar year or other appropriate reporting period 

with respect to which the Reporting Spanish Financial 

Institution acted as a custodian, broker, nominee, or 

otherwise as an agent for the Account Holder; 

(6) 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 (5) 

or (6) of this paragraph, the total gross amount paid or 

credited to the Account Holder with respect to the account 

during the calendar year or other appropriate reporting 

period with respect to which the Reporting Spanish 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 Spanish 

Reportable Account of each Reporting U.S. Financial Institution:
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(1) the name, address, and Spanish TIN of any person that is a 

resident of Spain and is an Account 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 of interest 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 or 61 of subtitle A of the U.S. Internal 

Revenue Code.

Article 3

Time and Manner of Exchange of Information

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

characterization of payments made with respect to a U.S. Reportable Account 

may be determined in accordance with the principles of Spain’s tax laws, and 

the amount and characterization of payments made with respect to a Spanish 

Reportable Account may be determined in accordance with principles of U.S. 

federal income tax law. 

2. For purposes of the exchange obligation in Article 2, the information 

exchanged shall identify the currency in which each relevant amount is 

denominated.

3. With respect to paragraph 2 of Article 2, information is to be obtained and 

exchanged with respect to 2013 and all subsequent years, except that:

a) In the case of Spain:

(1) the information to be obtained and exchanged with respect to 

2013 and 2014 is only the information described in 

subparagraphs (a)(1) to (a)(4); 

(2) the information to be obtained and exchanged with respect to 

2015 is the information described in subparagraphs (a)(1) to 
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(a)(7), except for gross proceeds described in subparagraph 

(a)(5)(B); and

(3) the information to be obtained and exchanged with respect to 

2016 and subsequent years is the information described in 

subparagraph (a)(1) to (a)(7);

b) In the case of the United States, the information to be obtained and 

exchanged with respect to 2013 and subsequent years is all of the 

information identified in subparagraph (b). 

4. Notwithstanding paragraph 3 of this Article, with respect to each 

Reportable Account that is a Preexisting Account, and subject to paragraph 4 of 

Article 6, the Parties are not required to obtain and include in the exchanged 

information the Spanish TIN or the U.S. TIN, as applicable, of any relevant 

person if such taxpayer identifying number is not in the records of the Reporting 

Financial Institution. In such case, the Parties shall obtain and include in the 

exchanged information the date of birth of the relevant person, if the Reporting 

Financial Institution has such date of birth in its records.

5. Subject to paragraphs 3 and 4 of this Article, the information described in 

Article 2 shall be exchanged within nine months after the end of the calendar 

year to which the information relates. Notwithstanding the foregoing, the 

information that relates to calendar year 2013 shall be exchanged no later than 

September 30, 2015.

6. The Competent Authorities of Spain and the United States shall enter into 

an agreement under the mutual agreement procedure provided for in Article 26 

of the Convention, which shall:

a) establish the procedures for the automatic exchange obligations 

described in Article 2; 

b) prescribe rules and procedures as may be necessary to implement 

Article 5; and

c) establish as necessary procedures for the exchange of the 

information reported under subparagraph 1(b) of Article 4.

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

other protections provided for in the Convention, including the provisions 

limiting the use of the information exchanged.
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Article 4

Application of FATCA to Spanish Financial Institutions

1. Treatment of Reporting Spanish Financial Institutions. Each 

Reporting Spanish Financial Institution shall be treated as complying with, and 

not subject to withholding under, section 1471 of the U.S. Internal Revenue 

Code if Spain complies with its obligations under Articles 2 and 3 with respect 

to such Reporting Spanish Financial Institution, and the Reporting Spanish 

Financial Institution:

a) identifies U.S. Reportable Accounts and reports annually to the 

Spanish Competent Authority the information required to be 

reported in subparagraph 2(a) of Article 2 in the time and manner 

described in Article 3;

b) for each of 2015 and 2016, reports annually to the Spanish 

Competent Authority the name of each Nonparticipating Financial 

Institution to which it has made payments and the aggregate 

amount of such payments;

c) complies with the registration requirements applicable to Financial 

Institutions in Partner Jurisdictions;

d) to the extent that a Reporting Spanish 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 subtitle A of

the U.S. Internal Revenue Code, (ii) a foreign partnership that has 

elected to act as a withholding foreign partnership (for purposes of 

both sections 1441 and 1471 of the U.S. Internal Revenue Code), 

or (iii) a foreign trust that has elected to act as a withholding 

foreign trust (for purposes of both sections 1441 and 1471 of the 

U.S. Internal Revenue Code), withholds 30 percent of any U.S. 

Source Withholdable Payment to any Nonparticipating Financial 

Institution; and 

e) in the case of a Reporting Spanish Financial Institution that is not 

described in subparagraph (d) of this paragraph and that makes a 

payment of, or acts as an intermediary with respect to, a U.S. 

Source Withholdable Payment to any Nonparticipating Financial 

Institution, the Reporting Spanish Financial Institution provides to 

any immediate payor of such U.S. Source Withholdable Payment 

the information required for withholding and reporting to occur 

with respect to such payment.
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Notwithstanding the foregoing, a Reporting Spanish Financial Institution with 

respect to which the conditions of this paragraph are not satisfied shall not be 

subject to withholding under section 1471 of the U.S. Internal Revenue Code 

unless such Reporting Spanish Financial Institution is identified by the IRS as a 

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

5.

2. Suspension of Rules Relating to Recalcitrant Accounts. The United 

States shall not require a Reporting Spanish Financial Institution to withhold tax 

under section 1471 or 1472 of the U.S. Internal Revenue Code with respect to 

an account held by a recalcitrant account holder (as defined in section 

1471(d)(6) of the U.S. Internal Revenue Code), or to close such account, if the 

U.S. Competent Authority receives the information set forth in subparagraph 

2(a) of Article 2, subject to the provisions of Article 3, with respect to such 

account.

3. Specific Treatment of Retirement Plans. The United States shall treat 

as a deemed-compliant FFI or exempt beneficial owner, as appropriate, for 

purposes of section 1471 of the U.S. Internal Revenue Code Spanish retirement 

plans described and identified in Annex II. For this purpose, a Spanish 

retirement plan includes an entity established or located in and regulated in 

Spain, or a predetermined contractual or legal arrangement, operated to provide 

pension or retirement benefits or earn income for providing such benefits under 

the laws of Spain and regulated with respect to contributions, distributions, 

reporting, sponsorship, and taxation. 

4. Identification and Treatment of Other Deemed-Compliant FFIs and 

Exempt Beneficial Owners. The United States shall treat each Non-Reporting 

Spanish 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 That Are Nonparticipating 

Financial Institutions. If a Spanish Financial Institution, that otherwise meets 

the requirements of 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 a 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, such Spanish Financial Institution shall continue to 

be in compliance with the terms of this Agreement and shall continue to be 

treated as a deemed-compliant FFI or exempt beneficial owner for purposes of 

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

a) the Spanish Financial Institution treats each such Related Entity or 
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branch as a separate Nonparticipating Financial Institution for 

purposes of all the reporting 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 or branch identifies its U.S. accounts and 

reports the information with respect to those accounts as required 

under 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 not 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 branch or Related Entity is located, and 

such branch or Related Entity is not used by the Spanish Financial 

Institution or any other Related Entity to circumvent the 

obligations under this Agreement or under section 1471 of the U.S. 

Internal Revenue Code, as appropriate.

Article 5

Collaboration on Compliance and Enforcement

1. Minor and Administrative Errors. Subject to any further terms set 

forth in a competent authority agreement executed pursuant to paragraph 6 of 

Article 3, a Competent Authority can make an inquiry directly to a Reporting 

Financial Institution in the other jurisdiction where it has reason to believe that 

administrative errors or other minor errors may have led to incorrect or 

incomplete information reporting or resulted in other infringements of this 

Agreement. The competent authority agreement may provide that a Competent 

Authority shall notify the Competent Authority of the other Party when the firstmentioned Competent Authority makes such an inquiry of a Reporting Financial 

Institution in the other jurisdiction regarding the Reporting Financial 

Institution’s compliance with the conditions set forth in this Agreement.

2. Significant Non-compliance.

a) A Competent Authority 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 
17

Authority of such other Party shall apply its domestic law 

(including applicable penalties) to address the significant noncompliance described in the notice. 

b) If, in the case of a Reporting Spanish Financial Institution, such 

enforcement actions do not resolve the non-compliance within a 

period of 18 months after notification of significant noncompliance is first provided, the United States shall treat the 

Reporting Spanish Financial Institution as a Nonparticipating 

Financial Institution. The IRS shall make available a list of all 

Reporting Spanish Financial Institutions and other Partner 

Jurisdiction Financial Institutions that are treated as 

Nonparticipating Financial Institutions pursuant to this paragraph.

3. Reliance on Third Party Service Providers. Each Party may allow 

Reporting Financial Institutions to use third party service providers to fulfill the 

obligations imposed on them by a Party, as contemplated in this Agreement, but 

these obligations shall remain the responsibility of the Reporting Financial 

Institutions.

4. Prevention of Avoidance. The Parties shall implement as necessary 

requirements to prevent Financial Institutions from adopting practices intended 

to circumvent the reporting required under this Agreement.

Article 6

Mutual Commitment to Continue to Enhance the Effectiveness of 

Information Exchange and Transparency

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

equivalent levels of reciprocal automatic information exchange with Spain. The 

United States is committed to further improve transparency and enhance the 

exchange relationship with Spain by pursuing the adoption of regulations and 

advocating and supporting relevant legislation to achieve such equivalent levels 

of reciprocal automatic exchange.

2. Treatment of Passthru Payments and Gross Proceeds. The Parties are 

committed to work together, along with other partners, to develop a practical 

and effective alternative approach to achieve the policy objectives of foreign 

passthru payment and gross proceeds withholding that minimizes burden. 

3. Development of Common Reporting and Exchange Model. The 

Parties are committed to working with other partners, the Organisation for 

Economic Co-operation and Development, and the European Union, on 
18

adapting the terms of this Agreement to a common model for automatic 

exchange of information, including the development of reporting and due 

diligence standards for financial institutions.

4. Documentation of Accounts Maintained as of January 1, 2014. With 

respect to Reportable Accounts that are Preexisting Accounts maintained by a 

Reporting Financial Institution:

a) The United States commits to establish, by January 1, 2017, for 

reporting with respect to 2017 and subsequent years, rules 

requiring Reporting U.S. Financial Institutions to obtain and report 

the Spanish TIN of each Account Holder of a Spanish Reportable 

Account as required pursuant to subparagraph 2(b)(1) of Article 2; 

and

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

respect to 2017 and subsequent years, rules requiring Reporting 

Spanish Financial Institutions to obtain the U.S. TIN of each 

Specified U.S. Person as required pursuant to subparagraph 2(a)(1) 

of Article 2.

Article 7

Consistency in the Application of FATCA to Partner Jurisdictions 

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

4 or Annex I of this Agreement relating to the application of FATCA to Spanish 

Financial Institutions afforded to another Partner Jurisdiction under a signed 

bilateral agreement pursuant to which the other Partner Jurisdiction commits to 

undertake the same obligations as Spain described in Articles 2 and 3 of this 

Agreement, and subject to the same terms and conditions as described therein 

and in Articles 5 through 9 of the Agreement. 

2. The United States shall notify Spain of any such more favorable terms 

and shall apply such more favorable terms automatically under this Agreement 

as if they were specified in this Agreement and effective as of the date of the 

entry into force of the agreement incorporating the more favorable terms.
19

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 consent of the Parties. 

Unless otherwise agreed upon, such an amendment shall enter into force 

through the same procedures as set forth in paragraph 1 of Article 10.

Article 9

Annexes

The Annexes form an integral part of this Agreement.

Article 10

Term of Agreement

1. The Parties shall notify each other in writing when their necessary 

internal procedures for entry into force have been completed. The Agreement 

shall enter into force on the date of the later of such written notifications, and 

shall continue in force until terminated. 

2. Either Party may terminate the 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 after 

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. 
20

In witness whereof, the undersigned, being duly authorized thereto by their 

respective Governments, have signed this Agreement. 

Done at _____, in duplicate, in the English and Spanish languages, both texts 

being equally authentic, this __ day of _____, 20__.

FOR THE UNITED STATES OF 

AMERICA:

FOR THE KINGDOM OF SPAIN:
21

ANNEX I 

DUE DILIGENCE OBLIGATIONS FOR IDENTIFYING AND 

REPORTING ON U.S. REPORTABLE ACCOUNTS AND ON 

PAYMENTS TO CERTAIN NONPARTICIPATING FINANCIAL

INSTITUTIONS

I. General

 

A. Spain shall require that Reporting Spanish Financial Institutions 

apply the due diligence procedures contained in this Annex I to identify 

U.S. Reportable Accounts and accounts held by Nonparticipating 

Financial Institutions. 

B. For purposes of the Agreement,

1. All dollar amounts shall be read to include the equivalent in 

other currencies.

2. The balance 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 balance or value threshold is to be determined as of 

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

balance or value shall be determined as of the last day of the 

reporting period that ends with or within that calendar year. 

4. Subject to paragraph II.E (1), an account shall be treated as a 

U.S. Reportable Account beginning as of the date it is identified as 

such pursuant to the due diligence procedures in this Annex I.

5. Unless otherwise provided, information with respect to a 

U.S. Reportable Account 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 of this 

Annex I, Spain may allow its Reporting Spanish Financial Institutions to 

rely on the procedures described in relevant U.S. Treasury Regulations to 

establish whether an account is a U.S. Reportable Account or an account 

held by a Nonparticipating Financial Institution. 

II. Preexisting Individual Accounts. The following rules and procedures 
22

apply for 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 Spanish Financial Institution 

elects otherwise, where the implementing rules in Spain provide 

for such an election, the following accounts are not required to be 

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

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

Individual Accounts with a balance or value that does not exceed 

$50,000 as of December 31, 2013.

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

Individual Accounts that are Cash Value Insurance Contracts and 

Annuity Contracts with a balance or value of $250,000 or less as of 

December 31, 2013.

3. Preexisting Individual Accounts that are Cash Value 

Insurance Contracts or Annuity Contracts, provided the law or 

regulations of Spain or the United States effectively prevents the 

sale of Cash Value Insurance Contracts or Annuity Contracts to 

U.S. residents, such as if the relevant Financial Institution does not 

have the required registration under U.S. law, and the law of Spain 

requires reporting or withholding with respect to insurance 

products held by residents of Spain.

4. Any Depository Account with a balance or value of $50,000 

or less.

B. Review Procedures for Preexisting Individual Accounts With a 

Balance or Value as of December 31, 2013, that Exceeds 

$50,000 ($250,000 for a Cash Value Insurance Contract or 

Annuity Contract), But Does Not Exceed $1,000,000 (“Lower 

Value Accounts”)

1. Electronic Record Search. The Reporting Spanish 

Financial Institution must review electronically searchable data 

maintained by the Reporting Spanish Financial Institution for any 

of the following U.S. indicia:

a) Identification of the Account Holder as a U.S. citizen 

or resident;
23

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 or U.S. “in-care-of” address);

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 “in-care-of” or “hold mail” address that is the sole

address the Reporting Spanish Financial Institution has on 

file for the Account Holder. In the case of a Preexisting 

Individual Account that is a Lower Value Account, an “incare-of” address outside the United States shall not be 

treated as U.S. indicia.

2. If none of the U.S. indicia listed in subparagraph B (1) of 

this section are discovered in the electronic search, then no further 

action is required until there is a change in circumstances described 

in subparagraph C (2) of this section with respect to the account 

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

account.

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

section are discovered in the electronic search, then the Reporting 

Spanish 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.

4. Notwithstanding a finding of U.S. indicia under 

subparagraph B (1) of this section, a Reporting Spanish Financial 

Institution is not required to treat an account as a U.S. Reportable 

Account if:

a) Where Account Holder information unambiguously 

indicates a U.S. place of birth, the Reporting Spanish 

Financial Institution obtains or has previously reviewed and 
24

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);

(2) a non-U.S. passport or other governmentissued identification evidencing the Account Holder’s 

citizenship or nationality in a country other than the 

United States; and

(3) a copy of the Account Holder’s Certificate of 

Loss of Nationality of the United States or a 

reasonable explanation of: 

(a) the reason the Account Holder does not 

have such a certificate despite renouncing U.S. 

citizenship; or

(b) the reason the Account Holder did not 

obtain U.S. citizenship at birth.

b) Where Account Holder information contains a

current U.S. mailing or residence address, or one or more 

U.S. telephone numbers that are the only telephone 

numbers associated with the account, the Reporting 

Spanish Financial Institution obtains or has previously 

reviewed and maintains a record of:

(1) a self-certification that the Account Holder is 

not a U.S. citizen or resident for tax purposes (which 

may be on an IRS Form W-8 or other similar agreed 

form); and

(2) a non-U.S. passport or other government-issued 

identification evidencing the Account Holder’s

citizenship or nationality in a country other than the 

United States.

c) Where Account Holder information contains standing 

instructions to transfer funds to an account maintained in 

the United States, the Reporting Spanish Financial 
25

Institution obtains or has previously reviewed and maintains 

a record of:

(1) a self-certification that the Account Holder is 

not a U.S. citizen or 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 

VI.D of this Annex I, establishing the Account 

Holder’s non-U.S. status.

d) Where Account Holder information contains a 

currently effective power of attorney or signatory authority 

granted to a person with a U.S. address, has an “in care 

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 

associated with the account), the Reporting Spanish 

Financial Institution obtains or has previously reviewed and 

maintains a record of:

(1) a self-certification that the Account Holder is 

not a U.S. citizen or 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

VI.D 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

1. Review of Preexisting Individual Accounts that are Lower 

Value Accounts for U.S. indicia must be completed by December 

31, 2015. 

2. If there is a change of circumstances with respect to a 

Preexisting Individual Account that is a Lower Value Account that 

results in one or more U.S. indicia described in subparagraph B (1) 

of this section being associated with the account, then Reporting 

Spanish Financial Institution must treat the account as a U.S. 
26

Reportable Account unless subparagraph B (4) of this section 

applies.

3. Except for Depository Accounts described in subparagraph A 

(4) of this section, any Preexisting Individual Account that has 

been identified as a U.S. Reportable Account under this section 

shall be treated as a U.S. Reportable Account in all subsequent 

years, unless the Account Holder ceases to be a Specified U.S. 

Person.

D. Enhanced Review Procedures for Preexisting Individual 

Accounts With a Balance or Value That Exceeds $1,000,000 as of 

December 31, 2013, or December 31 of Any Subsequent Year (“HighValue Accounts”)

1. Electronic Record Search. The Reporting Spanish 

Financial Institution must review electronically searchable data 

maintained by the Reporting Spanish Financial Institution for any 

of the U.S. indicia identified in subparagraph B (1) of this section.

2. Paper Record Search. If the Reporting Spanish Financial 

Institution’s electronically searchable databases include fields for 

and capture all of the information identified in subparagraph D (3) 

of this section, then no further paper record search is required. If 

the electronic databases do not capture all of this information, then 

with respect to High Value Accounts, the Reporting Spanish 

Financial Institution must also review the current customer master 

file and, to the extent not contained in the current customer master 

file, the following documents associated with the account and 

obtained by the Reporting Spanish Financial Institution within the 

last five years for any of the U.S. indicia identified in subparagraph 

B (1) of this section:

a) the most recent documentary evidence collected with 

respect to the account;

b) the most recent account opening contract or 

documentation;

c) the most recent documentation obtained by the 

Reporting Spanish Financial Institution pursuant to 

AML/KYC Procedures or for other regulatory purposes;
27

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 Spanish Financial Institution is not

required to perform the paper record search described in 

subparagraph D (2) of this section if the Reporting Spanish 

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 Spanish 

Financial Institution;

c) the Account Holder’s telephone number(s) currently 

on file, if any, with the Reporting Spanish Financial 

Institution; 

d) whether there are standing instructions to transfer 

funds in the account to another account (including an 

account at another branch of the Reporting Spanish Financial 

Institution or another Financial Institution);

e) whether there is a current “in care of” address or “hold 

mail” address for the Account Holder; and

f) whether there is any power of attorney or signatory 

authority for the account. 

4. Relationship Manager Inquiry for Actual Knowledge. In 

addition to the electronic and paper record searches described 

above, the Reporting Spanish Financial Institution must treat as 

U.S. Reportable Accounts any High Value Accounts assigned to a 

relationship manager (including any accounts aggregated with such 

account) if the relationship manager has actual knowledge that the 

Account Holder is a Specified U.S. Person.

5. Effect of Finding U.S. Indicia
28

a) If none of the U.S. indicia listed in subparagraph B (1) 

of this section are discovered in the enhanced review of High 

Value Accounts described above, and the account is not 

identified as held by a Specified U.S. Person in subparagraph 

D (4) of this section, then no further action is required until 

there is a change in circumstances described in subparagraph 

E (4) of this section.

b) If any of the U.S. indicia listed in 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

Spanish Financial Institution must treat the account as a U.S. 

Reportable Account unless subparagraph B (4) of this 

section applies.

c) Except for Depository Accounts described in 

paragraph A (4) of this section, any Preexisting Individual 

Account that has been identified as a U.S. Reportable 

Account under this section shall be treated as a U.S. 

Reportable Account in all subsequent years, unless the 

Account Holder ceases to be a Specified U.S. Person. 

E. Additional Procedures Applicable to High Value Accounts

1. If a Preexisting Individual Account is a High Value Account 

as of December 31, 2013, the Reporting Spanish Financial 

Institution must complete the enhanced review procedures 

described in paragraph D of this section with respect to such 

account by December 31, 2014. If based on this review such 

account is identified as a U.S. Reportable Account, the Reporting 

Spanish Financial Institution must report the required information 

about such account with respect to 2013 and 2014 in the first report 

on the account. For all subsequent years, information about the 

account should be reported on an annual basis.

2. If a Preexisting Individual Account is not a High Value 

Account as of December 31, 2013, but becomes a High Value 

Account as of the last day of a subsequent calendar year, the 

Reporting Spanish Financial Institution must complete the 

enhanced review procedures described in paragraph D of this 
29

section with respect to such account within six months after the last 

day of the calendar year in which the account becomes a High 

Value Account. If based on this review such account is identified 

as a U.S. Reportable Account, the Reporting Spanish Financial 

Institution must report the required information about such account 

with respect to the year in which it is identified as a U.S. 

Reportable Account and subsequent years on an annual basis.

3. Once a Reporting Spanish Financial Institution applies the 

enhanced review procedures set forth above to a High Value 

Account, the Reporting Spanish Financial Institution shall not be 

required to re-apply such procedures, other than the relationship 

manager inquiry in subparagraph D (4) of this section, to the same 

High Value Account in any subsequent year.

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

Value Account that results in one or more U.S. indicia described in 

subparagraph B (1) of this section being associated with the 

account, then the Reporting Spanish Financial Institution must treat 

the account as a U.S. Reportable Account unless subparagraph B 

(4) of this section applies.

5. A Reporting Spanish 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 Spanish 

Financial Institution shall be required to treat the new address as a 

change in circumstances and shall be required to obtain the 

appropriate documentation from the Account Holder.

III. New Individual Accounts. The following rules and procedures apply 

for identifying U.S. Reportable Accounts among accounts held by individuals 

and opened on or after January 1, 2014 (“New Individual Accounts”).

A. Accounts Not Required to Be Reviewed, Identified or 

Reported. Unless the Reporting Spanish Financial Institution elects 

otherwise where the implementing rules in Spain provide for such an 

election:

1. A New Individual Account that is a Depository Account is 

not required to be reviewed, identified, or reported as a U.S. 

Reportable Account unless the account balance exceeds $50,000 at 
30

the end of any calendar year or other appropriate reporting period. 

2. A New Individual Account that is a Cash Value Insurance 

Contract is not required to be reviewed, identified, or reported as a 

U.S. Reportable Account unless the Cash Value exceeds $50,000 at 

the end of any calendar year or other appropriate reporting period. 

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

Accounts not described in paragraph A of this section, upon account 

opening, (or within 90 days after the end of the calendar year in which the 

account ceases to be described in paragraph A of this section), the 

Reporting Spanish Financial Institution must obtain a self-certification 

which may be part of the account opening documentation, that allows the 

Reporting Spanish 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 considered to be resident in the United States for tax 

purposes, even if the Account Holder is also a tax resident of another 

country) and confirm the reasonableness of such self-certification based 

on the information obtained by the Reporting Spanish Financial 

Institution in connection with the opening of the account, including any 

documentation collected pursuant to AML/KYC Procedures.

C. If the self-certification establishes that the Account Holder is 

resident in the United States for tax purposes, the Reporting Spanish

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

and obtain a self-certification that includes the Account Holder’s U.S. 

TIN (which may be an IRS Form W-9 or other similar agreed form).

D. If there is a change of circumstances with respect to a New 

Individual Account that causes the Reporting Spanish Financial 

Institution to know or have reason to know that the original selfcertification is incorrect or unreliable, the Reporting Spanish Financial 

Institution cannot rely on the original self-certification and must obtain a 

valid self-certification that establishes whether the Account Holder is a 

U.S. citizen or resident for U.S. tax purposes. If the Reporting Spanish 

Financial Institution is unable to obtain a valid self-certification, the 

Reporting Spanish Financial Institution must treat the account as a U.S. 

Reportable Account.

IV. Preexisting Entity Accounts. The following rules and procedures apply 

for purposes of identifying U.S. Reportable Accounts and accounts held by a 

Nonparticipating Financial Institutions among Preexisting Accounts held by 

entities (“Preexisting Entity Accounts”).
31

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

Reported. Unless the Reporting Spanish Financial Institution elects 

otherwise, where the implementing rules in Spain provide for such an 

election, Preexisting Entity Accounts with account balances that do not 

exceed $250,000 as of December 31, 2013, are not required to be 

reviewed, identified, or reported as U.S. Reportable Accounts until the 

account balance exceeds $1,000,000.

 

B. Entity Accounts Subject to Review. Preexisting Entity Accounts 

that have an account balance or value that exceeds $250,000 as of 

December 31, 2013, and Preexisting Entity Accounts that initially do not 

exceed $250,000 but the account balance of which later exceeds 

$1,000,000 must be reviewed in accordance with the procedures set forth 

in paragraph D of this section. 

C. Entity Accounts With Respect to Which Reporting is Required. 

With respect to Preexisting Entity Accounts described in paragraph B of 

this section, only accounts that are held by one or more entities that are 

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

Controlling Persons who are U.S. citizens or residents shall be treated as 

U.S. Reportable Accounts. In addition, accounts held by 

Nonparticipating Financial Institutions shall be treated as accounts for 

which aggregate payments as described in paragraph 1(b) of Article 4 of 

the Agreement are reported to the Spanish Competent Authority.

D. Review Procedures for Identifying Entity Accounts With 

Respect to Which Reporting is Required. For Preexisting Entity 

Accounts described in paragraph B of this section, the Reporting Spanish 

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 a Nonparticipating Financial 

Institution:

1. Determine Whether the Entity is a Specified U.S. Person.

a) Review information maintained for regulatory or 

customer relationship purposes (including information 

collected pursuant to AML/KYC Procedures) to determine 

whether the information indicates that the Entity Account 

Holder is a U.S. Person. For this purpose, information 

indicating that the entity is a U.S. Person includes a U.S. 
32

place of incorporation or organization, or a U.S. address.

b) If the information indicates that the Entity Account 

Holder is a U.S. Person, the Reporting Spanish Financial 

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

Account unless it obtains a self-certification from the 

Account Holder (which may be on an IRS Form W-8 or W9, 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 purposes (including information 

collected pursuant to AML/KYC Procedures) to determine 

whether the information indicates that the Entity Account 

Holder is a Financial Institution.

b) If the information indicates that the Entity Account 

Holder is a Financial Institution, then the account is not a 

U.S. Reportable Account. 

3. Determine Whether a Financial Institution is a

Nonparticipating Financial Institution Payments to Which Are 

Subject to Aggregate Reporting Under Paragraph 1(b) of 

Article 4 of the Agreement.

a) Subject to subparagraph (b) of this paragraph, if the 

Account Holder is a Spanish Financial Institution or other 

Partner Jurisdiction Financial Institution, then no further 

review, identification, or reporting is required with respect to 

the account.

b) A Spanish Financial Institution or other Partner 

Jurisdiction Financial Institution shall be treated as a 

Nonparticipating Financial Institution if it is identified as 

such by the IRS pursuant to paragraph 2 of Article 5 of the 

Agreement.

c) If the Account Holder, is not a Spanish Financial 

Institution or other Partner Jurisdiction Financial Institution, 
33

then the Reporting Spanish Financial Institution must treat 

the entity as a Nonparticipating Financial Institution 

payments to which are reportable under paragraph 1(b) of 

Article 4 of the Agreement, unless the Reporting Spanish 

Financial Institution:

(1) Obtains a self-certification (which may be on an 

IRS Form W-8 or similar agreed form) from the entity 

that it is a certified deemed-compliant FFI, an exempt 

beneficial owner, or an excepted FFI, as those terms 

are defined in relevant U.S. Treasury Regulations; or

(2) In the case of a participating FFI or registered 

deemed-compliant FFI, verifies the entity’s FATCA 

identifying number on a published IRS FFI list.

4. Determine Whether an Account Held by an NFFE Is a 

U.S. Reportable Account. With respect to an Account Holder of a 

Preexisting Entity Account that is not identified as either a U.S. 

Person or a Financial Institution, the Reporting Spanish Financial 

Institution must identify (i) whether the entity has Controlling 

Persons, (ii) whether the entity is a Passive NFFE, and (iii) whether 

any of the Controlling Persons of the entity is a citizen or resident 

of the United States. In making these determinations the Reporting 

Spanish Financial Institution should follow the guidance in subparagraphs (a) through (d) of this paragraph in the order most 

appropriate under the circumstances.

a) For purposes of determining the Controlling Persons 

of an entity, a Reporting Spanish Financial Institution may 

rely on information collected and maintained pursuant to 

AML/KYC Procedures.

b) For purposes of determining whether the entity is a 

Passive NFFE, the Reporting Spanish Financial Institution 

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 entity is 

an Active NFFE.

c) For purposes of determining whether a Controlling 
34

Person of a Passive NFFE is a citizen or resident of the 

United States for tax purposes, a Reporting Spanish 

Financial Institution may rely on: 

(1) Information collected and maintained pursuant 

to AML/KYC Procedures in the case of a Preexisting 

Entity Account held by one or more NFFEs with an 

account balance 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 that exceeds 

$1,000,000. 

d) If any Controlling Person of a Passive NFFE is a 

citizen or resident of the United States, the account shall be 

treated as a U.S. Reportable Account.

E. Timing of Review and Additional Procedures Applicable to 

Preexisting Entity Accounts

1. Review of Preexisting Entity Accounts with an account 

balance or value that exceeds $250,000 as of December 31, 2013, 

must be completed by December 31, 2015.

2. Review of Preexisting Entity Accounts with a balance or 

value that does not exceed $250,000 as of December 31, 2013, but 

exceeds $1,000,000 as of December 31 of a subsequent year, must 

be completed within six months after the end of the calendar year 

in which the account balance exceeds $1,000,000.

3. If there is a change of circumstances with respect to a 

Preexisting Entity Account that causes the Reporting Spanish 

Financial Institution to know or have reason to know that the selfcertification or other documentation associated with an account is 

incorrect or unreliable, the Reporting Spanish Financial Institution 

must re-determine the status of the account in accordance with the 

procedures set forth in paragraph D of this section.

V. New Entity Accounts. The following rules and procedures apply to 

accounts held by entities and opened on or after January 1, 2014 (“New Entity 
35

Accounts”). 

A. The Reporting Spanish Financial Institution must determine 

whether the Account Holder is: (i) a Specified U.S. Person; (ii) a Spanish 

Financial Institution or other Partner Jurisdiction Financial Institution; 

(iii) a participating FFI, a deemed-compliant FFI, an exempt beneficial 

owner, or an excepted FFI, as those terms are defined in relevant U.S. 

Treasury Regulations; or (iv) an Active NFFE or Passive NFFE. 

B. A Reporting Spanish Financial Institution may determine that an 

Account Holder is an Active NFFE, a Spanish Financial Institution, or 

other Partner Jurisdiction Financial Institution if the Reporting Spanish 

Financial Institution reasonably determines that the entity has such status 

on the basis of information that is publicly available or in the possession 

of the Reporting Spanish Financial Institution. 

C. In all other cases, a Reporting Spanish Financial Institution must 

obtain a self-certification from the Account Holder to establish the 

Account Holder’s status.

 

1. If the Entity Account Holder is a Specified U.S. Person, the 

Reporting Spanish Financial Institution must treat the account as a 

U.S. Reportable Account.

2. If the Entity Account Holder is a Passive NFFE, the

Reporting Spanish Financial Institution must identify the 

Controlling Persons as determined under AML/KYC Procedures, 

and must determine whether any such person is a citizen or resident 

of the United States on the basis of a self-certification from the 

Account Holder or such person. If any such person is a citizen or 

resident of the United States, the account shall be treated as a U.S. 

Reportable Account.

3. If the Entity Account Holder is: (i) a U.S. Person that is not 

a Specified U.S. Person; (ii) subject to subparagraph C (4) of this 

section, a Spanish Financial Institution or other Partner Jurisdiction 

Financial Institution; (iii) a participating FFI, a deemed-compliant 

FFI, an exempt beneficial owner, or an excepted FFI, 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 of which 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.
36

4. If the Entity Account Holder is a Nonparticipating Financial 

Institution (including a Spanish Financial Institution or other 

Partner Jurisdiction Financial Institution that is identified by the 

IRS as a Nonparticipating Financial Institution pursuant to

paragraph 2 of Article 5 of the Agreement), then the account is not 

a U.S. Reportable Account, but payments to the Account Holder 

must be reported as contemplated in paragraph 1(b) of Article 4 of 

the Agreement.

VI. Special Rules and Definitions. The following additional rules and 

definitions apply in implementing the due diligence procedures described 

above:

A. Reliance on Self-Certifications and Documentary Evidence. A 

Reporting Spanish Financial Institution may not rely on a selfcertification or documentary evidence if the Reporting Spanish Financial 

Institution knows or has reason to know that the self-certification or 

documentary evidence is incorrect or unreliable.

B. Definitions. The following definitions apply for purposes of this 

Annex I.

1. AML/KYC Procedures. “AML/KYC Procedures” means the 

customer due diligence procedures of a Reporting Spanish 

Financial Institution pursuant to the anti-money laundering or 

similar requirements of Spain to which such Reporting Spanish 

Financial Institution is subject. 

2. NFFE. An “NFFE” means any Non-U.S. Entity that is not an 

FFI as defined in relevant U.S. Treasury Regulations, and also 

includes any Non-U.S. Entity that is resident in Spain or other 

Partner Jurisdiction and that is not a Financial Institution.

3. Passive NFFE. A “Passive NFFE” means any NFFE that is not 

(i) an Active NFFE or (ii) a withholding foreign partnership or 

withholding foreign trust pursuant to relevant U.S. Treasury 

Regulations.

4. Active NFFE. An “Active NFFE” means any NFFE that meets 

any of the following criteria:
37

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 of which is traded on an 

established securities market;

c) The NFFE is organized in a U.S. Territory and all of the 

owners of the payee are bona fide residents of that U.S. 

Territory;

d) The NFFE is a non-U.S. government, a government of a 

U.S. Territory, an international organization, a non-U.S. 

central bank of issue, or an Entity wholly owned by one 

or more of the foregoing; 

e) Substantially all of the activities of the NFFE consist of 

holding (in whole or in part) the outstanding stock of, and 

providing financing and services to, one or more 

subsidiaries that engage in trades or businesses other than 

the business of a Financial Institution, except that an 

NFFE shall not qualify for this status if the NFFE 

functions (or holds itself out) as an investment fund, such 

as a private equity fund, venture capital fund, leveraged 

buyout fund or any investment vehicle whose purpose is 

to acquire or fund companies and then hold interests in 

those companies as capital assets for investment 

purposes;

f) The NFFE is not yet operating a business and has no 

prior operating history, but is investing capital into assets 

with the intent to operate a business other than that of a 

Financial Institution; provided, that the NFFE shall not 

qualify for this exception after the date that is 24 months 

after the date of the initial organization of the NFFE;

g) The NFFE was not a Financial Institution in the past five 

years, and is in the process of liquidating its assets or is 
38

reorganizing with the intent to continue or recommence 

operations in a business other than that of a Financial 

Institution;

h) The NFFE primarily engages in financing and hedging 

transactions with or for Related Entities that are not 

Financial Institutions, and does not provide financing or 

hedging services to any Entity that is not a Related 

Entity, provided that the group of any such Related 

Entities is primarily engaged in a business other than that 

of a Financial Institution; or

i) The NFFE meets all of the following requirements:

i. It is established and maintained in its country of 

residence exclusively for religious, charitable, 

scientific, artistic, cultural, or educational purposes;

ii. It is exempt from income tax in its country 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 Entity’s country of 

residence or the Entity’s formation documents do not 

permit any income or assets of the Entity 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 Entity’s charitable activities, or 

as payment of reasonable compensation for services 

rendered, or as payment representing the fair market 

value of property which the Entity has purchased; 

and

v. The applicable laws of the Entity’s country of 

residence or the Entity’s formation documents 

require that, upon the Entity’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 

Entity’s country of residence or any political 

subdivision thereof.
39

C. Account Balance Aggregation and Currency Translation Rules

1. Aggregation of Individual Accounts. For purposes of 

determining the aggregate balance or value of accounts held by an 

individual, a Reporting Spanish Financial Institution shall be 

required to aggregate all accounts maintained by the Reporting 

Spanish Financial Institution, or Related Entities, but only to the 

extent that the Reporting Spanish Financial Institution’s 

computerized systems link the accounts by reference to a data 

element such as client number or taxpayer identification number, 

and allow account balances to be aggregated. Each holder of a 

jointly held account shall be attributed the entire balance or value 

of the jointly held account for purposes of applying the aggregation 

requirements described in this paragraph.

2. Aggregation of Entity Accounts. For purposes of 

determining the aggregate balance or value of accounts held by an 

Entity, a Reporting Spanish Financial Institution shall be required 

to take into account all accounts held by Entities that are 

maintained by the Reporting Spanish Financial Institution, or 

Related Entities, to the extent that the Reporting Spanish Financial 

Institution’s computerized systems link the accounts by reference 

to a data element such as client number or taxpayer identification 

number and allow account balances to be aggregated.

3. Special Aggregation Rule Applicable to Relationship 

Managers. For purposes of determining the aggregate balance or 

value of accounts held by a person to determine whether an 

account is a High Value Account, a Reporting Spanish Financial 

Institution shall also be required, in the case of any accounts that a 

relationship manager knows or has reason to know are directly or 

indirectly owned, controlled, or established (other than in a 

fiduciary capacity) by the same person, to aggregate all such 

accounts.

4. Currency Translation Rule. For purposes of determining 

the balance or value of accounts denominated in a currency other 

than the U.S. dollar, a Reporting Spanish Financial Institution must 

convert the dollar threshold amounts described in this Annex I into 

such currency using a published spot rate determined as of the last 

day of the calendar year preceding the year in which the Reporting 

Spanish Financial Institution is determining the balance or value.
40

D. Documentary Evidence. For purposes of this Annex I, acceptable 

documentary evidence includes any of the following:

1. A certificate of residence issued by an appropriate tax 

official of the country in which the payee claims to be a resident.

2. With respect to an individual, any valid identification issued 

by an authorized government body (for example, a government or 

agency thereof, or a municipality), that includes the individual’s 

name and is typically used for identification purposes.

3. With respect to an Entity, any official documentation issued 

by an authorized government body (for example, a government or 

agency thereof, or a municipality) that includes the name of the 

Entity and either the address of its principal office in the country 

(or U.S. Territory) in which it claims to be a resident or the country 

(or U.S. Territory) in which the Entity was incorporated or 

organized.

4. With respect to an account maintained in a jurisdiction with 

anti-money laundering rules that have been approved by the IRS in 

connection with a QI agreement (as described in relevant U.S. 

Treasury Regulations), any of the documents other than a Form W8 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.
41

ANNEX II

NON-REPORTING SPANISH FINANCIAL INSTITUTIONS 

AND PRODUCTS

This Annex II may be updated by a mutual agreement entered into between the 

Competent Authorities of Spain and the United States: (1) to include additional 

entities, accounts, and products that present a low risk of being used by U.S. 

Persons to evade U.S. tax and that have similar characteristics to the entities, 

accounts, and products identified in this Annex II as of the date of entry into 

force of the Agreement; or (2) to remove entities, accounts, and products that, 

due to changes in circumstances, no longer present a low risk of being used by 

U.S. Persons to evade U.S. tax. Procedures for reaching such a mutual 

agreement may be included in the mutual agreement described in paragraph 6 of 

Article 3 of the Agreement.

I. Exempt Beneficial Owners. The following categories of institutions are 

Non-Reporting Spanish Financial Institutions that are treated as exempt 

beneficial owners for purposes of section 1471 of the U.S. Internal Revenue 

Code:

A. Governmental Entities

Instituto de Crédito Oficial 

Consorcio de Compensación de Seguros 

Comisión Nacional del Mercado de Valores 

B. Central Bank

Banco de España

C. Retirement Funds

1. Any fund regulated under the Amended Text of the Law on 

pension funds and pension schemes (Texto refundido de la Ley 

sobre fondos y planes de pensiones), passed by Legislative Royal 

Decree 1/2002 of 29th November. 

2. Any entity defined under Article 64 of the Amended Text of the 

Law on the regulation and monitoring of private insurances (Texto 

refundido de la Ley de ordenación y supervisión de los seguros 
42

privados) passed by Legislative Royal Decree 6/2004 of 29th 

October, provided that in the case of mutual funds all participants 

are employees; promoters and sponsoring partners are the 

companies, institutions or individual entrepreneurs to which the 

employees are engaged; and benefits are exclusively derived from 

the social welfare agreement between both parties, as well as any 

other comparable entity to them regulated within the scope of the 

political subdivisions (Comunidades Autónomas). 

II. Deemed-Compliant Financial Institutions. 

A. The following categories of institutions are Non-Reporting Spanish 

Financial Institutions that are treated as deemed-compliant FFIs for 

purposes of section 1471 of the U.S. Internal Revenue Code:

1. Small Financial Institutions with Local Client Base

A Spanish Financial Institution that meets all of the following 

requirements:

a. The Financial Institution must be licensed and regulated 

under the laws of Spain; 

b. The Financial Institution must have no fixed place of 

business outside Spain; 

c. The Financial Institution must not solicit Account 

Holders outside Spain. For this purpose, a Financial 

Institution shall not be considered to have solicited Account 

Holders outside of Spain merely because it operates a 

website, provided that the website does not specifically 

indicate that the Financial Institution provides accounts or 

services to nonresidents or otherwise target or solicit U.S. 

customers;

d. The Financial Institution must be required under the tax 

laws of Spain to perform either information reporting or 

withholding of tax with respect to accounts held by residents 

of Spain;
43

e. At least 98 percent of the accounts by value provided by 

the Financial Institution must be held by residents (including 

residents that are entities) of Spain or another Member State 

of the European Union; 

f. Subject to subparagraph 1(g), below, beginning on 

January 1, 2014, the Financial Institution does not provide 

accounts to (i) any Specified U.S. Person who is not a 

resident of Spain (including a U.S. Person that was a 

resident of Spain when the account was opened but 

subsequently ceases to be a resident of Spain), (ii) a 

Nonparticipating Financial Institution, or (iii) any Passive 

NFFE with Controlling Persons who are U.S. citizens or 

residents;

g. On or before January 1, 2014, the Financial Institution 

must implement policies and procedures to monitor whether 

it provides any account held by a person described in 

subparagraph 1(f), and if such an account is discovered, the 

Financial Institution must report such account as though the 

Financial Institution were a Reporting Spanish Financial 

Institution or close such account; 

h. With respect to each account that is held by an individual 

who is not a resident of Spain or by an entity, and that is 

opened prior to the date that the Financial Institution 

implements the policies and procedures described in 

subparagraph 1(g), above, the Financial Institution must 

review those accounts in accordance with the procedures 

described in Annex I applicable to Preexisting Accounts to 

identify any U.S. Reportable Account or account held by a 

Nonparticipating Financial Institution, and must close any 

such accounts that were identified, or report on such 

accounts as though the Financial Institution were a 

Reporting Spanish Financial Institution; 

i. Each Related Entity of the Financial Institution must be 

incorporated or organized in Spain and must meet the 

requirements set forth in this paragraph; and

j. The Financial Institution must not have policies or 

practices that discriminate against opening or maintaining 
44

accounts for individuals who are Specified U.S. Persons and 

who are residents of Spain.

B. Certain Collective Investment Vehicles

In the case of an Investment Entity that is a collective investment vehicle 

regulated under the laws of Spain: 

a) if all of the interests in the collective investment vehicle 

(including debt interests in excess of $50,000) are held by or 

through one or more Financial Institutions that are not 

Nonparticipating Financial Institutions, such collective investment 

vehicle will be treated as a deemed-compliant FFI for purposes of 

section 1471 of the U.S. Internal Revenue Code, and the reporting 

obligations of any Investment Entity (other than a Financial 

Institution through which interests in the collective investment 

vehicle are held) will be deemed fulfilled with respect to interests 

in the collective investment vehicle; or 

b) if the collective investment vehicle is not described in 

paragraph (a), consistent with paragraph 3 of Article 5 of the 

Agreement, if the information required to be reported by the 

collective investment vehicle under the Agreement with respect to 

interests in the collective investment vehicle is reported by the 

collective investment vehicle or another Investment Entity, the 

reporting obligations of all other Investment Entities required to 

report with respect to the interests in the collective investment 

vehicle will be deemed fulfilled with respect to such interests.

III. Exempt Products. The following categories of accounts and products 

established in Spain and maintained by a Spanish Financial Institution shall not 

be treated as Financial Accounts, and therefore shall not be U.S. Reportable 

Accounts or accounts held by a Nonparticipating Financial Institution, under the 

Agreement:

A. Certain Retirement Accounts or Products

1. Annuity contracts which substantiate commitments on pensions 

under First Additional Provision of the Amended Text of the Law 

on pension funds and pension schemes (Legislative Royal Decree 

1/2002 of 29th November), provided that the benefit amount is 

established pursuant to a collective bargaining agreement between 
45

employers and the representatives of a trade union or set out by 

Law.

2. Accounts held by pension plans described in section I.C.

3. Accounts held by mutualidades de previsión social

4. Planes de previsión asegurados

5. Planes de previsión social empresarial

6. Seguros de dependencia

B. Certain Other Tax-Favored Accounts or Products

1. Plan individual de ahorro sistemático