The Foreign Account Tax Compliance Act (FATCA) is a United States federal law that requires US persons, including individuals who live outside the US, to report their financial accounts held outside of the US, and requires foreign financial institutions to report to the Internal Revenue Service (IRS) about their US clients.
How does Norway comply with FATCA?
- Norway has entered into a Model 1 Intergovernmental Agreement (IGA) with the US tax authorities (IRS) in 2013.
- The Norwegian tax authorities and the IRS agreed to exchange information about US persons having accounts with financial institutions in Norway.
- Link to the IGA (PDF)
- The IGA has been transposed into Norwegian law.
- The regulation is available here (in Norwegian) and the guidance is available here (PDF) (in Norwegian)
Who is impacted by FATCA?
- Foreign Financial Institutions and US persons worldwide.
- Asset managers in Norway: SKAGEN as an FFI has to comply with FATCA and report their US clients to the Norwegian Tax Authorities (and they in turn to the IRS).
- US persons: all US persons with accounts outside the US (including US persons living outside the US) will have to report their financial accounts to the US Tax Authorities.
What is SKAGEN's FATCA status?
- SKAGEN is fully FATCA compliant and has adapted its systems in order to collect the required information we will need to report to the Norwegian tax authorities
- SKAGEN AS, the management company, is a Sponsoring Entity under FATCA
- SKAGEN has registered with the US tax authority via the IRS FATCA portal
- SKAGEN is a reporting Model 1 FFI (a reporting foreign financial institution under a Model 1 IGA)
What is SKAGEN's GIIN?
- The GIIN for SKAGEN AS is: ZFN02A.00000.SP.578
Do SKAGEN's funds have GIINs?
- SKAGEN's funds are Sponsored Entities and received a GIIN after registering with the IRS
- The GIINs for SKAGEN's funds are:
- SKAGEN Global: ZFN02A.00001.SF.578
- SKAGEN Kon-Tiki: ZFN02A.00004.SF.578
- SKAGEN Vekst: ZFN02A.00005.SF.578
- SKAGEN Focus: ZFN02A.00017.SF.578
- SKAGEN m2: ZFN02A.00012.SF.578
- SKAGEN Insight: ZFN02A.00023.SF.578
- SKAGEN Tellus: ZFN02A.00007.SF.578
- SKAGEN Credit EUR: ZFN02A.00016.SF.578
- SKAGEN Avkastning: ZFN02A.00006.SF.578
- SKAGEN Select 100: ZFN02A.00018.SF.578
- SKAGEN Select 80: ZFN02A.00019.SF.578
- SKAGEN Select 60: ZFN02A.00020.SF.578
- SKAGEN Select 30: ZFN02A.00021.SF.578
- SKAGEN Select 15: ZFN02A.00022.SF.578
Do SKAGEN's branches have GIINs?
- As SKAGEN AS is classified as a Sponsoring Entity, it had to get a GIIN for the Management Company and in due course for all the funds, but not for the branches.
What is SKAGEN's policy regarding FATCA clients and/or US clients?
- SKAGEN's funds are not registered with and authorised by the US regulator (SEC) and therefore SKAGEN cannot accommodate US clients in its funds as this would be breaching US law.
- SKAGEN states this in chapter 18 of its prospectus
- By taking on FATCA clients (US citizens or US residents), SKAGEN would be in breach of US law requiring registration of foreign fund managers and their funds in the US
- SKAGEN therefore regrettably cannot take on any US clients/FATCA clients in its funds
Whom in SKAGEN can I contact with my questions?
- SKAGEN has a FATCA project and dedicated team to ensure the correct implementation of the regulations
- All questions should be directed to the following email address: firstname.lastname@example.org