Five jurisdictions sit on the IRS list of places that do not issue foreign Tax Identification Numbers: Australia, Bermuda, the British Virgin Islands, the Cayman Islands, and Japan.1Internal Revenue Service. List of Jurisdictions That Do Not Issue Foreign TINs A few other countries, including Brunei Darussalam, have no dedicated TIN for individuals and rely on national identity card numbers instead. Among the countries that do not issue tax identification numbers, the practical consequence is the same: financial institutions and withholding agents need a different answer for the TIN field, and you need to know which one.
The Five Jurisdictions on the IRS List
The IRS maintains a specific list of jurisdictions whose residents are not required to provide a foreign TIN to U.S. withholding agents.1Internal Revenue Service. List of Jurisdictions That Do Not Issue Foreign TINs The five entries and their FATCA agreement types:
- Australia (Model 1 IGA)
- Bermuda (Model 2 IGA)
- British Virgin Islands (Model 1 IGA)
- Cayman Islands (Model 1 IGA)
- Japan (Model 2 IGA)
If you are a withholding agent dealing with an account holder who resides in one of these five, you do not have to collect a foreign TIN from that person.
Australia and Japan can look out of place on a list dominated by small offshore jurisdictions. Both run major tax systems. Australia issues Tax File Numbers, but Australian law does not require residents to obtain one; individuals apply voluntarily.2OECD. Australia – Information on Tax Identification Numbers Because the identifier is not issued universally, Australia qualifies for the IRS list. Japan sits on the list under its Model 2 agreement with the United States for a comparable reason.
Other Countries Without a Universal TIN
The IRS list is narrow. It exists to tell U.S. withholding agents when they can skip the foreign TIN field. Beyond FATCA, several other countries also have no universal TIN for individuals.
The British Virgin Islands is the cleanest case. The BVI does not issue Tax Identification Numbers or any equivalent tax identifier at all.3OECD. British Virgin Islands – Information on Tax Identification Numbers Bermuda has no universal TIN either, though businesses interact with the tax system through Company Registration Numbers, Entity Registration Numbers, and Payroll Tax Numbers.
Brunei Darussalam does not issue a TIN for individuals. It uses the National Registration Identity Card number as a functional equivalent, and the NRIC is issued automatically to citizens, permanent residents, and temporary residents.4Organisation for Economic Co-operation and Development. Information on Tax Identification Numbers – Brunei Darussalam
These arrangements cluster in smaller jurisdictions, places with no personal income tax, and countries where a national identity system already handles the tracking a TIN would otherwise perform.
What Counts as a Functional Equivalent
Countries without a dedicated TIN still identify people for tax and regulatory purposes. The OECD’s Common Reporting Standard recognizes several categories of identifier as functional equivalents of a TIN: social security or insurance numbers, citizen or personal identification codes, resident registration numbers for individuals, and business or company registration codes for entities.5OECD. Consolidated Text of the Common Reporting Standard 2025
Some jurisdictions offer a government verification service that issues a unique reference number or confirmation code, which financial institutions can use to confirm identity and tax residence. Under the CRS, that reference number also qualifies as a functional equivalent.5OECD. Consolidated Text of the Common Reporting Standard 2025 If your country has one of these systems, the number you already hold is what the financial institution needs.
Filling Out a Self-Certification Form Without a TIN
When you open an account and cannot provide a TIN, the bank hands you a self-certification form. The OECD’s standard individual self-certification form under CRS includes three reason codes for the missing TIN field:6OECD. Individual Tax Residency Self-Certification Form
- Reason A: Your country of tax residence does not issue TINs to its residents.
- Reason B: You are unable to obtain a TIN, and you must explain why.
- Reason C: No TIN is required, because the jurisdiction’s domestic law does not require financial institutions to collect it.
Reason A is the right choice if you live somewhere like the BVI that simply does not issue TINs. Reason B triggers a written explanation and more scrutiny. Reason C fits jurisdictions where a TIN exists but local law does not require its collection for financial reporting. Picking the wrong code, or leaving the field blank, is a common error that delays account opening and prompts follow-up requests.
What Happens When No TIN Is Provided
Living in a jurisdiction that does not issue TINs will not, on its own, cause a compliance problem. The IRS has said the absence of a TIN does not automatically lead to a determination of significant non-compliance.7Internal Revenue Service. Frequently Asked Questions FATCA Compliance Legal When a TIN is missing, the IRS issues an error notice and gives the financial institution 120 days to correct it. Only after weighing the facts does the IRS decide whether non-compliance exists.
A different situation carries much heavier consequences. A U.S. person who has a Social Security Number but declines to provide it to a foreign bank is not covered by any of this. The bank may close the account or apply withholding, and a foreign financial institution that fails to satisfy its FATCA registration requirements faces 30 percent withholding on withholdable payments it receives.7Internal Revenue Service. Frequently Asked Questions FATCA Compliance Legal
The line to keep in mind: if your jurisdiction genuinely does not issue TINs, the reason codes on the self-certification form exist for you, and both FATCA and CRS accommodate you. If you have a TIN and choose not to share it, that is a different problem with different consequences.