rp-21-32.pdf

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26 CFR 601.601: Rules and regulations
(Also Part 1, §§ 6049; 1.6049-4, 1.6049-8)

Implementation of Nonresident Alien Deposit Interest Regulations

Rev. Proc. 2021-32

SECTION 1. PURPOSE
This revenue procedure provides a list of the jurisdictions with which the United
States has in effect a relevant information exchange agreement such that the
reporting requirement of §§ 1.6049-4(b)(5) and 1.6049-8(a) of the Income Tax
Regulations may apply with respect to certain deposit interest paid to residents of
such jurisdictions.
This revenue procedure also provides a list of the jurisdictions with which the
Department of the Treasury (Treasury Department) and the Internal Revenue Service
(IRS) have determined that it is appropriate to have an automatic exchange relationship
with respect to the information collected under §§ 1.6049-4(b)(5) and 1.6049-8(a).
These lists are updated and restated versions of those set forth in Rev. Proc. 2020-15,
2020-23 I.R.B. 905. Chile has been added in Section 3 of this revenue procedure to the
list of jurisdictions with which the United States has in effect a relevant information
exchange agreement. The Dominican Republic and Singapore have been added in
Section 4 of this revenue procedure to the list of jurisdictions with which the Treasury

Department and the IRS have determined that it is appropriate to have an automatic
exchange relationship.
SECTION 2. BACKGROUND
Sections 1.6049-4(b)(5) and 1.6049-8(a), as revised by TD 9584, 2012-20 I.R.B.
900, require the reporting of certain deposit interest paid to nonresident alien individuals
on or after January 1, 2013. Section 1.6049-4(b)(5) provides that in the case of interest
aggregating $10 or more paid to a nonresident alien individual (as defined in section
7701(b)(1)(B)) that is reportable under § 1.6049-8(a), the payor is required to make an
information return on Form 1042-S, Foreign Person’s U.S. Source Income Subject to
Withholding, for the calendar year in which the interest is paid.
Interest that is reportable under § 1.6049-8(a) is interest described in section
871(i)(2)(A) that relates to a deposit maintained at an office within the United States.
The regulations also provide that such deposit interest is reportable only if paid to a
resident of a jurisdiction that is identified as a jurisdiction with which the United States
has in effect an income tax or other convention or bilateral agreement relating to the
exchange of tax information within the meaning of section 6103(k)(4), under which the
competent authority is the Secretary of the Treasury or the Secretary’s delegate and the
United States agrees to provide, as well as receive, information. Finally, the regulations
provide that jurisdictions are so identified in an applicable revenue procedure (see
§ 601.601(d)(2)) as of December 31 before the calendar year in which the interest is
paid. The preamble to the regulations (at 2012-20 I.R.B. 901-02) notes that the IRS will
not exchange information with another jurisdiction, even if an information exchange
agreement is in effect, if there are concerns about confidentiality, safeguarding of data

exchanged, the use of the information, or other factors that would make the exchange of
information inappropriate.
Rev. Proc. 2012-24, 2012-20 I.R.B. 913, was published contemporaneously with the
publication of TD 9584 to provide a list of those jurisdictions with which the United States
has in effect an information exchange agreement, such that interest paid to residents of
such jurisdictions must be reported by payors to the extent required under §§ 1.6049-
4(b)(5) and 1.6049-8(a), and to provide a separate list identifying those jurisdictions with
which the automatic exchange of the information collected under the regulations has been
determined by the Treasury Department and the IRS to be appropriate. Before issuance
of this Rev. Proc. 2021-32, the most current versions of those lists were set forth in Rev.
Proc. 2020-15.
SECTION 3. JURISDICTIONS OF RESIDENCE WITH RESPECT TO WHICH THE
DEPOSIT INTEREST REPORTING REQUIREMENT APPLIES

The following are the jurisdictions with which the United States has in effect an
income tax or other convention or bilateral agreement relating to the exchange of tax
information within the meaning of section 6103(k)(4) pursuant to which the United
States agrees to provide, as well as receive, information and under which the
competent authority is the Secretary of the Treasury or the Secretary’s delegate:

Jurisdiction Rev. Proc. First Identifying Jurisdiction
Antigua & Barbuda 2012-24
Argentina 2018-36
Aruba 2012-24
Australia 2012-24
Austria 2012-24
Azerbaijan 2012-24

Bangladesh 2012-24
Barbados 2012-24
Belgium 2012-24
Bermuda 2012-24
Brazil 2014-64
British Virgin Islands 2012-24
Bulgaria 2012-24
Canada 2012-24
Cayman Islands 2014-64
Chile 2021-32
China 2012-24
Colombia 2014-64
Costa Rica 2012-24
Croatia 2014-64
Curaçao 2014-64
Cyprus 2012-24
Czech Republic 2012-24
Denmark 2012-24
Dominica 2012-24
Dominican Republic 2012-24
Egypt 2012-24
Estonia 2012-24
Faroe Islands 2017-46
Finland 2012-24
France 2012-24
Georgia 2019-23
Germany 2012-24
Gibraltar 2012-24
Greece 2012-24
Greenland 2017-46
Grenada 2012-24
Guernsey 2012-24
Guyana 2012-24
Honduras 2012-24
Hong Kong 2014-64
Hungary 2012-24
Iceland 2012-24
India 2012-24
Indonesia 2012-24
Ireland 2012-24
Isle of Man 2012-24
Israel 2012-24
Italy 2012-24
Jamaica 2012-24

Japan 2012-24
Jersey 2012-24
Kazakhstan 2012-24
Korea, Republic of 2012-24
Latvia 2012-24
Liechtenstein 2012-24
Lithuania 2012-24
Luxembourg 2012-24
Malta 2012-24
Marshall Islands 2012-24
Mauritius 2014-64
Mexico 2012-64
Moldova 2018-36
Monaco 2012-24
Morocco 2012-24
Netherlands 2012-24
Netherlands special municipalities:
Bonaire, Sint Eustatius, and Saba
2012-24
New Zealand 2012-24
Norway 2012-24
Pakistan 2012-24
Panama 2012-24
Peru 2012-24
Philippines 2012-24
Poland 2012-24
Portugal 2012-24
Romania 2012-24
Russian Federation 2012-24
Saint Lucia 2016-56
Singapore 2020-15
Sint Maarten 2014-64
Slovak Republic 2012-24
Slovenia 2012-24
South Africa 2012-24
Spain 2012-24
Sri Lanka 2012-24
Sweden 2012-24
Switzerland 2012-24
Thailand 2012-24
Trinidad and Tobago 2012-24
Tunisia 2012-24
Turkey 2012-24
Ukraine 2012-24
United Kingdom 2012-24

Venezuela 2012-24

SECTION 4. JURISDICTIONS WITH WHICH THE TREASURY DEPARTMENT AND
THE IRS HAVE DETERMINED THAT AUTOMATIC EXCHANGE OF DEPOSIT
INTEREST INFORMATION IS APPROPRIATE

The following list identifies the jurisdictions with which the automatic exchange of
the information collected under §§ 1.6049-4(b)(5) and 1.6049-8 has been determined
by the Treasury Department and the IRS to be appropriate:

Jurisdiction Rev. Proc. First Memorializing
Determination on Automatic Exchange
with Jurisdiction
Australia 2014-64
Azerbaijan 2016-18
Belgium 2017-31
Brazil 2015-50
Canada 2012-24
Colombia 2017-31
Croatia 2017-46
Curaçao 2019-23
Cyprus 2019-23
Czech Republic 2015-50
Denmark 2014-64
Dominican Republic 2021-32
Estonia 2015-50
Finland 2014-64
France 2014-64
Germany 2014-64
Gibraltar 2015-50
Greece 2018-36
Guernsey 2014-64
Hungary 2015-50
Iceland 2015-50
India 2015-50
Ireland 2014-64
Isle of Man 2014-64
Israel 2016-56
Italy 2014-64

Jamaica 2016-18
Jersey 2014-64
Korea, Republic of 2016-56
Latvia 2015-50
Liechtenstein 2015-50
Lithuania 2015-50
Luxembourg 2015-50
Malta 2014-64
Mauritius 2014-64
Mexico 2014-64
Netherlands 2014-64
New Zealand 2015-50
Norway 2014-64
Panama 2017-46
Poland 2015-50
Portugal 2017-31
Saint Lucia 2016-56
Singapore 2021-32
Slovak Republic 2016-18
Slovenia 2015-50
South Africa 2015-50
Spain 2014-64
Sweden 2015-50
United Kingdom 2014-64

SECTION 5. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2020-15 is superseded.
SECTION 6. EFFECTIVE DATES
For purposes of the reporting requirement of § 1.6049-4(b)(5), the list of jurisdictions
in Section 3 of this revenue procedure is effective: (i) with respect to Chile, for interest
paid on or after January 1, 2022; and (ii) with respect to each other listed jurisdiction, for
interest paid on or after January 1 of the calendar year following the issuance of the
revenue procedure (as cited in Section 3) first identifying the jurisdiction as having in
effect an agreement with the United States as described in § 1.6049-8(a).
The list of jurisdictions in Section 4 of this revenue procedure is effective from the

date of issuance of this revenue procedure with respect to information reported to the
IRS pursuant to §§ 1.6049-4(b)(5) and 1.6049-8(a) for any tax year for which the
jurisdiction was included in the list in Section 3. The revenue procedure citations in the
Section 4 list are included for historical reference.
SECTION 7. DRAFTING INFORMATION
The principal authors of this revenue procedure are Jackie B. Manasterli and
Michelle R. Phillips of the Office of Associate Chief Counsel (International). For further
information regarding this revenue procedure, contact Ms. Manasterli or Ms. Phillips at
(202) 317-6941 (not a toll-free call).