Declaration of Understanding 

Regarding the Agreement between the United States of America and the Slovak Republic 

to Improve International Tax Compliance and to Implement F ATCA 

At the signing today of the Agreement between the United States of America and the Slovak 

Republic to Improve International Tax Compliance and to Implement FATCA (hereinafter the 

"Agreement"), the representatives of the United States of America and the Slovak Republic wish 

to confirm their understanding of the following: 

With reference to paragraph 7 of Article 3 (Time and Manner of Exchange of Information) 

of the Agreement 

It is understood that paragraph 1 sentences 3 through 5 of Article 27 of the Convention between 

the United States and the Slovak Republic for the A voidance of Double Taxation and the 

Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, done at Bratislava on 

October 8, 1993, applies to all information exchanged under the Agreement and sentence 5 of 

that paragraph applies accordingly for all persons or authorities in case the exchanged 

information is disclosed in public court proceedings or in judicial decisions. 

With reference to paragraph 1 of Article 10 (Term of Agreement) of the Agreement 

The United States understands that the Slovak Republic plans to present the Agreement to its 

parliament for its approval together with draft legislation that is to implement the provisions of 

the Agreement with the goal of having the Agreement and the legislation enter into force not 

later than September 30, 2015. Based on this understanding, as of the date of signature of the 

Agreement, the United States Department of the Treasury intends to treat each Slovak Financial 

Institution, as that term is defined in the Agreement, as complying with, and not subject to 

withholding under section 1471 ofthe U.S. Internal Revenue Code during such time as the 

Slovak Republic is pursuing the necessary internal procedures for entry into force of the 

Agreement. The United States further understands that the Slovak Republic's Ministry of 

Finance intends to contact the United States Department of the Treasury as soon as it is aware 

that there might be a delay in the Slovak internal approval process for entry into force of the 

Agreement such that the Slovak Republic would not be able to provide its notification under 

paragraph 1 of Article 10 of the Agreement prior to September 30, 2015. If upon consultation 

with the Slovak Republic, the United States Department of the Treasury receives credible 

assurances that such a delay is likely to be resolved in a reasonable period oftime, the United 

States Department of the Treasury may decide to continue to apply FA TCA to Slovak Financial 

Institutions in the manner described above as long as the United States Department of the 
Treasury assesses that the Slovak Republic is likely to be able to send its notification under 

paragraph 1 of Article 10 by September 30, 2016. It is understood that should the Agreement 

enter into force after September 30, 2015, any information that would have been reportable under 

the Agreement thereafter (and prior to its entry into force) had the Agreement been in force by 

September 30, 2015, is owed on the next September 30 following the date of entry into force. 

With reference to Subparagraph l(c) of Article 4 of the Agreement 

It is understood that the Slovak Republic intends for Slovak Financial Institutions to comply with 

the registration requirements applicable to Financial Institutions in Partner Jurisdictions by 

registering with the Internal Revenue Service and obtaining a Global Intermediary Identification 

Number ("GIIN") from the Internal Revenue Service. 

With reference to Subparagraph 2(a)(3) of Article 2 of the Agreement 

It is further understood that the Slovak Republic intends for each Reporting Slovak Financial 

Institution to use a GIIN issued by the Internal Revenue Service as the identifying number 

referenced in Subparagraph 2(a)(3) of Article 2 of the Agreement. 

With reference to Registration Requirements in Annex II 

It is understood that the Slovak Republic intends for Slovak Financial Institutions described in 

Annex II to comply with the registration requirements applicable to Financial Institutions in 

Partner Jurisdictions by registering with the Internal Revenue Service and obtaining a Global 

Intermediary Identification Number ("GIIN") from the Internal Revenue Service. 

With reference to Central Securities Depositories 

It is understood that, in the case of securities registered in a Central Securities Depository of the 

Slovak Republic acting according to the Act No. 566/2001 CoiL on Securities and Investment 

services that are held by or through one or more other Financial Institutions that are not 

Nonparticipating Financial Institutions, the relevant Financial Accounts are to be treated as held 

by such other Financial Institutions, and such other Financial Institutions are to be responsible 

for any reporting required with respect to such Financial Accounts. In accordance with 

paragraph 3 of Article 5 of the Agreement, the Central Securities Depository of the Slovak 

Republic may report on behalf of such other Financial Institutions. 

With reference to VI.B.4(j) of Annex I 

It is understood that Foundations (as non-profit organizations) according to the Act No. 34/2002 

Coli. on Foundations and amending the Civil Order as later amended are described by Section 

VI.B.4(j) of Annex I. 
Signed at~~ in duplicate, in the English and Slovak languages, this 1>1 day of __W_, 

201r. 0 0 

FOR THE UNITED STATES 

OF AMERICA: 

FOR THE SLOVAK 

REPUBLIC: