Notice 2023-11 provides reporting relief to Model 1 FFIs who cannot obtain U.S. TINs for their pre-existing accounts that are U.S. reportable accounts if they follow the procedures in the Notice.
HMRC stated that for the FATCA returns for the calendar year 2022 (due on May 31st, 2023) Financial Institutions (“FIs”) are permitted to use either the TIN codes issued in 2021 or the updated TIN codes released in 2023 for the purpose of reporting missing U.S. TINs.
It should be noted that, concerning reporting calendar years up to and including 2022, FIs can report an account without a valid U.S. TIN by entering “000000000” in the TIN field.
The updated codes shall be used for reporting the calendar years 2023 and 2024 to be eligible for relief.
The IRS has also published an update to FATCA FAQ 6 on reporting.