MEMORANDUM OF UNDERSTANDING REGARDING THE. AGREEMENT
BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE
GOVERNMENT OF THE ARGENTINE REPUBLIC TO IMPROVE INTERNATIONAL

TAX COMPLIANCE AND TO IMPLEMENT FATCA

Atthe signing: today of the Agreement between the Government of the United States of America
and the Government of the Argentine Republic.to Improve International Tax Compliance and to
Implement FATCA (hereinafter the “Agreement”), the representatives of the United States‘and
Argentina wish to corifirm their understanding of the following:

An FFI Agreemént, as defined in paragraph 1(nn) of Article 1 of the Agreement, that is in effect
for an Argentine Financial Institution that is registered with the IRS on the day immediately.
before entry into force of the. Agreement is expected not to be-renewed and therefore-to expire'in
accordance with the terms of such FFI Agreement with respect to the Argentine Financial
Institution. The FFI Agreement is expected to continue to apply to any branches‘of the
Argentine Financial Institution that are covered by the FF1 Agreement and are located in another
jurisdiction.

An Argentine Financial [nstitution that has. registered with the [RS prior to the:date of entry-into
force of the Agreement and has not had its status revoked is expected to be allowed to continue
to use.the same Global Intermediary Identification Number (GIN) that it obtained when it.
registered with the IRS, provided that the Argentine Financial Institution complies with the
following steps. Upon entry. into force of the Agreement, and once the IRS modifies the status.of
an. Argentine Financial Institution (other than an Argentine Financial Institution that is a branch
of a Financial Institution-not resident in Argentina) on the IRS FATCA Registration Portal to
“registration: incomplete”, the Argentine Financial Institution, in order to continue-to use its
GIIN, is expected to log on to the IRS FATCA Registration Portal and resubmit its registration.
To ensure. that the Argentine Financial Institution appears on the monthly IRS.FFI List, the
Argentine Financial Institution should resubmit its régistration. within 20 days-after the entry into
force of the Agreement. An updated FFI List is posted on the first day of each month, and only
includes financial institutions and branches that are in “approved” status on the first.day of the
month ard have been approved at least five business. days prior to the first day of the month. In
the case of an Argentine Financial Institution that is 4 branch of a Financial Institution not
resident in Argentina, no action needs to be taken on the [RS FATCA Registration Portal as a
result of the entry into force.of the Agreement.

Each Argentine Financial Institution that has a change in chapter 4 status,under the U.S. Intemal
Revenue Code (for example, a change. from Participating FFI status to Reporting Model 1 FFI
status) is expected to provide to each withholding agent, within 30 days after such change in
status, either.a new withholding certificate or oral or written confirmation (including by email) of
the-change in the Argentine Financial Institution’s chapter’4 status.


Signed at Buenos Aires, in duplicate, this 5 day of December, 2022, in the English language,

which is an official text. A Spanish language text of this Memorandum of Understanding may
be:prepated, which would be considered equally official upon. an excharige of diplomatic-notes
between the United States and Argentina confirming its conformity with the English language
text.

FOR THE GOVERNMENT OF
THE UNITED STATES OF AMERICA:

Mar RY bak,