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Form W-8EXP Instructions

Instructions for Form W-8EXP, Certificate of Foreign Government or Other Foreign Organization for United States Tax Withholding and Reporting

Rev. October 2023

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  • Form W-8EXP - Certificate of Foreign Government or Other Foreign Organization for United States Tax Withholding and Reporting
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Department of the Treasury  
Internal Revenue Service  
Instructions for Form  
W-8EXP  
(Rev. October 2023)  
Certificate of Foreign Government or Other Foreign Organization for United States  
Tax Withholding and Reporting  
Section references are to the Internal Revenue Code  
unless otherwise noted.  
Withholding rules. Foreign persons are subject to U.S.  
tax at a 30% rate on payments they receive from U.S.  
sources that consist of:  
Future Developments  
For the latest information about developments related to  
Form W-8EXP and its instructions, such as legislation  
enacted after they were published, go to IRS.gov/  
Interest (including certain original issue discount (OID));  
Dividends;  
Rents;  
Royalties;  
Premiums;  
Annuities;  
Compensation for, or in expectation of, services  
What’s New  
performed;  
Substitute payments in a securities lending transaction;  
Purpose of form. This section has been revised to  
provide additional background on the withholding regimes  
that may apply to payments to foreign entities and the  
exemptions to withholding that may be claimed with Form  
W-8EXP. These revisions are not intended to be  
substantive changes.  
or  
Other fixed or determinable annual or periodical gains,  
profits, or income.  
This tax is imposed on the gross amount paid and is  
generally collected by withholding under section 1441 or  
1442 on that amount. Certain payments made to foreign  
private foundations are instead subject to tax at a 4% rate  
under section 1443.  
Under chapter 4, withholdable payments made to a  
foreign entity are generally subject to withholding at a 30%  
rate unless the entity has established an exemption to  
withholding based on a valid chapter 4 status.  
Gain or loss of a foreign person on the disposition of a  
U.S. real property interest (USRPI) is taken into account  
as if the gain or loss is effectively connected with a U.S.  
trade or business under section 897. The transferee is  
generally required to withhold tax from the amount  
realized under section 1445. Certain distributions by  
qualified investment entities (QIEs) that are attributable to  
the disposition of USRPIs are also subject to withholding  
under section 1445. Gain or loss of a foreign person that  
is a qualified holder (as defined in Regulations section  
1.897(l)-1(d)) on the disposition of a USRPI or on a  
portion of a distribution from a qualified investment entity  
that is attributable to the disposition of USRPIs is exempt  
from tax under section 897 and from withholding under  
section 1445. The amount realized by a foreign  
Qualified foreign pension funds. These instructions  
have been updated to reflect final regulations published in  
December 2022 (87 FR 80042) regarding qualified foreign  
pension funds and claiming an exemption to withholding  
under section 1445.  
Non-private foundation status. The instructions to  
line 13c have been updated for revisions to the supporting  
information required for an entity qualifying under section  
501(c)(3) to represent that it is not a foreign private  
foundation. These revisions generally relate to  
modifications to Rev. Proc. 92-94, 1992-2 C.B. 507  
(previously referenced in these instructions) that were  
made in Rev. Proc. 2017-53, 2017-40 I.R.B. 263.  
General Instructions  
Purpose of Form  
If you receive certain types of income, you must provide  
Form W-8EXP to:  
Establish that you are not a U.S. person;  
Claim that you are the beneficial owner of the income  
partnership all the interests of which are held by qualified  
holders (a withholding qualified holder as defined in  
Regulations section 1.1445-1(g)(11)) on the disposition of  
a USRPI or a distribution from a QIE that is attributable to  
the disposition of USRPIs is exempt from withholding  
under section 1445.  
for which Form W-8EXP is given; and  
Claim a reduced rate of, or exemption from, withholding  
as a foreign government, international organization,  
foreign central bank of issue, foreign tax-exempt  
organization, foreign private foundation, or a government  
of a U.S. territory.  
Foreign persons are also subject to tax at graduated  
rates on income they earn that is considered effectively  
connected with a U.S. trade or business. If a foreign  
person holds an interest in a partnership that conducts a  
U.S. trade or business, the foreign person is considered to  
be engaged in a U.S. trade or business. The partnership is  
In addition, a withholding qualified holder under section  
1445 may use a Form W-8EXP to establish that it is  
treated as a non-foreign person and claim an exemption to  
withholding pursuant to section 897(l) (relating to qualified  
foreign pension funds).  
Nov 7, 2023  
Cat. No. 25903G  
required to withhold tax under section 1446(a) on the  
foreign person's allocable share of the partnership's  
effectively connected taxable income (ECTI). A foreign  
person that directly or indirectly disposes of an interest in  
a partnership that conducts a U.S. trade or business may  
have gain treated as effectively connected income under  
section 864(c)(8). Under section 1446(f), the transferee  
purchasing that partnership interest is generally required  
to withhold a tax equal to 10% of the amount realized.  
foreign government, international organization, foreign  
central bank of issue, foreign tax-exempt organization,  
foreign private foundation, or government of a U.S.  
territory must provide a Form W-8EXP to a withholding  
agent or payer with all necessary documentation. The  
withholding agent or payer of the income may rely on a  
valid Form W-8EXP to treat the payment, credit, or  
allocation associated with the Form W-8EXP as being  
made to a foreign government, international organization,  
foreign central bank of issue, foreign tax-exempt  
organization, foreign private foundation, or government of  
a U.S. territory that is exempt from withholding at the 30%  
rate (or, where appropriate, subject to withholding at a 4%  
rate).  
For purposes of section 1445, a withholding qualified  
holder may establish an exemption from tax under section  
897 by providing a Form W-8EXP to a withholding agent  
or transferee. A withholding qualified holder is not exempt  
from withholding under section 1441 or 1442 by virtue of  
its status as a withholding qualified holder.  
Exemptions to withholding. In general, payments to a  
foreign government (including a foreign central bank of  
issue wholly owned by a foreign sovereign) from  
investments in the United States in stocks, bonds, other  
domestic securities, financial instruments held in the  
execution of governmental financial or monetary policy,  
and interest on deposits in banks in the United States are  
exempt from tax under section 892 and exempt from  
withholding under sections 1441 and 1442. Payments  
other than those described above, including income  
derived in the United States from the conduct of a  
commercial activity, income received from a controlled  
commercial entity (including gain from the disposition of  
any interest in a controlled commercial entity), and income  
received by a controlled commercial entity, do not qualify  
for exemption from tax under section 892 or exemption  
from withholding under sections 1441 and 1442. See  
Temporary Regulations section 1.892-3T. In addition,  
certain distributions to a foreign government from a real  
estate investment trust (REIT) may not be eligible for relief  
from withholding and may be subject to withholding at  
21% (35% for distributions made before January 1, 2018)  
of the gain realized. For the definition of “commercial  
activities,see Temporary Regulations section 1.892-4T.  
For purposes of section 1446(a), a partner may provide  
a Form W-8EXP to reduce its ECTI subject to withholding  
if it is a:  
Foreign tax-exempt organization (under section 501(c))  
receiving an allocable share of income that is not  
includible under sections 512 and 513, or  
Qualified holder under section 1445 receiving an  
allocable share of income subject to section 897. See  
Regulations section 1.1446-1(c)(2)(ii)(G).  
In addition chapter 4 requires withholding agents to  
identify the chapter 4 status of payees receiving  
withholdable payments to determine whether withholding  
applies under chapter 4. Under chapter 4, certain foreign  
governments, foreign central banks, international  
organizations, and foreign entities described in section  
501(c) (other than an insurance company described in  
section 501(c)(15)) are not subject to withholding under  
chapter 4. A withholding agent may request this Form  
W-8EXP to establish your chapter 4 status and avoid  
withholding.  
In general, payments to an international organization  
from investment in the United States in stocks, bonds and  
other domestic securities, interest on deposits in banks in  
the United States, and payments from any other source  
within the United States are exempt from tax under  
section 892 and exempt from withholding under sections  
1441 and 1442. See Temporary Regulations section  
1.892-6T. Payments to a foreign central bank of issue  
(whether or not wholly owned by a foreign sovereign) or to  
the Bank for International Settlements from obligations of  
the United States or of any agency or instrumentality  
thereof, or from interest on deposits with persons carrying  
on the banking business, are also generally exempt from  
tax under section 895 and exempt from withholding under  
sections 1441 and 1442. In addition, payments to a  
foreign central bank of issue from bankers’ acceptances  
are exempt from tax under section 871(i)(2)(C) and  
exempt from withholding under sections 1441 and 1442.  
Chapter 4 also requires participating foreign financial  
institutions (FFIs) and certain registered  
deemed-compliant FFIs to document entity account  
holders in order to determine their chapter 4 status  
regardless of whether withholding applies to any  
payments made to the entities. If you maintain an account  
with an FFI and have a chapter 4 status shown in Part I,  
line 4 of this form, provide this Form W-8EXP when  
requested by the FFI in order to document your chapter 4  
status.  
Payments to a foreign tax-exempt organization of  
certain types of U.S. source income are also generally  
exempt from tax and exempt from withholding. Gross  
investment income of a foreign private foundation,  
however, is subject to withholding under section 1443(b)  
at a rate of 4%.  
Payments to a government of a territory of the United  
States are generally exempt from tax and withholding  
under section 115(2).  
Additional information. For additional information and  
instructions for the withholding agent, see the Instructions  
Who must provide Form W-8EXP. You must give Form  
W-8EXP to the withholding agent or payer if you are:  
A foreign government, international organization,  
foreign central bank of issue, foreign tax-exempt  
organization, foreign private foundation, or government of  
a U.S. territory receiving an amount subject to withholding  
under sections 1441 through 1443 or a withholdable  
To establish eligibility for exemption from 30% tax and  
withholding under sections 892, 895, 501(c), or 115(2), a  
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Instructions for Form W-8EXP (Rev. 10-2023)  
payment subject to chapter 4, or are such an entity  
person will be the one from whom you receive the  
payment (including the transferee of a USRPI), who  
credits your account, or a partnership that allocates  
income to you. Generally, a separate Form W-8EXP must  
be given to each withholding agent.  
Give Form W-8EXP to the person requesting it before  
the payment is made, credited, or allocated to you or your  
account. If you qualify for an exemption to tax, but do not  
provide this form, the withholding agent may have to  
withhold tax at the highest applicable rate. If you receive  
more than one type of income from a single withholding  
agent, the withholding agent may require you to submit a  
Form W-8EXP for each different type of income.  
maintaining an account with an FFI requesting this form;  
A withholding qualified holder claiming an exemption to  
withholding under section 1445;  
A foreign tax-exempt organization claiming an  
exemption to withholding under section 1446(a) on your  
allocable share of ECTI that is not includible under section  
512 and section 513 for purposes of computing unrelated  
business taxable income;  
A qualified holder claiming an exemption to withholding  
under section 1446(a) on its allocable share of ECTI that  
is income subject to section 897; or  
Otherwise establishing your status as a non-U.S.  
person (for an entity permitted to use this form under  
applicable regulations).  
Expiration of Form W-8EXP. Generally, a Form W-8EXP  
remains in effect indefinitely until a change of  
When not to use Form W-8EXP. Do not use Form  
circumstances makes any information provided on the  
form incorrect. In some cases, however, Form W-8EXP  
will remain valid only for a period starting on the date the  
form is signed and ending on the last day of the third  
succeeding calendar year. For example, a Form W-8EXP  
provided on February 15, 2022, by a controlled entity of a  
foreign government would be subject to the 3-year validity  
period and thus would expire on December 31, 2025, for  
sections 1441 through 1443 purposes. For more  
W-8EXP if you are:  
Not a foreign government, international organization,  
foreign central bank of issue, foreign tax-exempt  
organization, foreign private foundation, or government of  
a U.S. territory receiving amounts subject to withholding  
under sections 1441 through 1443 claiming the  
applicability of section 115(2), 501(c), 892, 895, or  
1443(b). Instead, provide Form W-8BEN-E, or Form  
W-8ECI. For example, if you are a foreign tax-exempt  
organization claiming a benefit under an income tax treaty,  
provide Form W-8BEN-E.  
exceptions to the indefinite validity period, see:  
Regulations section 1.1441-1(e)(4)(ii) for sections 1441  
through 1443 purposes,  
Regulation section 1.1445-5(b)(3)(ii)(B)(3) (2 years) for  
Receiving a withholdable payment from a withholding  
agent requesting this form and you do not have a  
chapter 4 status identified in Part I, line 4 of this form.  
1445 purposes,  
Regulation section 1.1446-1(c)(2)(iv) for section 1446  
Acting as an intermediary (that is, acting not for your  
purposes, and  
own account, but for the account of others as an agent,  
nominee, or custodian). Instead, provide Form W-8IMY.  
Regulations section 1.1471-3(c)(6)(ii) for chapter 4  
purposes.  
Receiving income that is effectively connected with the  
Change in circumstances. If a change in circumstances  
makes any information on the Form W-8EXP you have  
submitted incorrect, you must notify the withholding agent  
within 30 days of the change in circumstances and you  
must file a new Form W-8EXP or other appropriate form. A  
withholding qualified holder that fails to qualify as a  
withholding qualified holder due to a change in  
conduct of a trade or business in the United States.  
Instead, provide Form W-8ECI, when applicable.  
A tax-exempt organization receiving unrelated business  
taxable income subject to withholding under section  
1443(a). Instead, provide Form W-8BEN-E or Form  
W-8ECI (as applicable) for this portion of your income.  
A foreign partnership, a foreign simple trust, a foreign  
circumstances must notify the relevant entity before any  
further dispositions or distributions. See Regulations  
section 1.1445-5(b)(3)(ii)(B)(3).  
complex trust, or a foreign grantor trust. Instead, provide  
Form W-8ECI, W-8BEN-E, or Form W-8IMY. However, a  
foreign grantor trust is required to provide documentation  
of its grantor or other owner for purposes of section 1446.  
See Regulations section 1.1446-1. In addition, a foreign  
partnership may use this form to establish its status as a  
withholding qualified holder exempt from withholding  
under section 1445.  
Definitions  
Amounts exempt from tax under section 895. Section  
895 generally excludes from gross income and exempts  
from U.S. taxation income a foreign central bank of issue  
receives from obligations of the United States (or of any  
agency or instrumentality thereof) or from interest on  
deposits with persons carrying on the banking business  
unless such obligations or deposits are held for, or used in  
connection with, the conduct of commercial banking  
functions or other commercial activities of the foreign  
central bank of issue.  
A foreign partnership receiving a payment subject to  
withholding under section 1445 and you don't qualify as a  
withholding qualified holder under section 1445 because  
not all of your partners are qualified holders. In such a  
case, see Regulations section 1.1445-3 for procedures to  
obtain a withholding certificate to reduce withholding.  
A foreign partnership claiming an exemption or  
adjustment to withholding under section 1446(f) on an  
amount realized on the transfer of an interest in a  
partnership.  
Amounts exempt from tax under section 892. Only a  
foreign government or an international organization as  
defined below qualifies for exemption from taxation under  
section 892. Section 892 generally excludes from gross  
income and exempts from U.S. taxation income a foreign  
government receives from investments in the United  
Giving Form W-8EXP to the withholding agent. Do  
not send Form W-8EXP to the IRS. Instead, give it to the  
person who is requesting it from you. Generally, this  
Instructions for Form W-8EXP (Rev. 10-2023)  
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States in stocks, bonds, or other domestic securities;  
financial instruments held in the execution of  
governmental financial or monetary policy; and interest on  
deposits in banks in the United States of monies  
belonging to the foreign government. Income of a foreign  
government from any of the following sources is not  
exempt from U.S. taxation.  
Foreign partnerships, foreign simple trusts, and foreign  
grantor trusts are not the beneficial owners of income paid  
to the partnership or trust. The beneficial owners of  
income paid to a foreign partnership are generally the  
partners in the partnership, provided that the partner is not  
itself a partnership, foreign simple or grantor trust,  
nominee, or other agent. The beneficial owners of income  
paid to a foreign simple trust (that is, a foreign trust that is  
described in section 651(a)) are generally the  
The conduct of any commercial activity.  
A controlled commercial entity.  
The disposition of any interest in a controlled  
beneficiaries of the trust, if the beneficiary is not a foreign  
partnership, foreign simple or grantor trust, nominee, or  
other agent. The beneficial owners of income paid to a  
foreign grantor trust (that is, a foreign trust to the extent  
that all or a portion of the income of the trust is treated as  
owned by the grantor or another person under sections  
671 through 679) are the persons treated as the owners of  
the trust. The beneficial owners of income paid to a  
foreign complex trust (that is, a foreign trust that is not a  
foreign simple trust or foreign grantor trust) is the trust  
itself.  
commercial entity. For the definition of “commercial  
activity,” see Temporary Regulations section 1.892-4T.  
Section 892 also generally excludes from gross income  
and exempts from U.S. taxation income of an international  
organization received from investments in the United  
States in stocks, bonds, or other domestic securities and  
interest on deposits in banks in the United States of  
monies belonging to the international organization or from  
any other source within the United States.  
Amounts subject to withholding. Generally, an amount  
subject to withholding under sections 1441 through 1443  
is an amount from sources within the United States that is  
fixed or determinable annual or periodical (FDAP) income.  
FDAP income is all income included in gross income,  
including interest (as well as OID), dividends, rents,  
royalties, and compensation. FDAP income does not  
include most gains from the sale of property (including  
market discount and option premiums), as well as other  
specific items of income described in Regulations section  
1.1441-2 (such as interest on bank deposits and  
short-term OID).  
For purposes of sections 1445 and 1446(f), the amount  
subject to withholding is generally the transferor's amount  
realized.  
For purposes of section 1446(a), the amount subject to  
withholding is the foreign partner’s allocable share of the  
partnership’s ECTI.  
An amount subject to chapter 4 withholding is an  
amount of U.S. source FDAP income that is also a  
withholdable payment as defined in Regulations section  
1.1473-1(a) to which an exception does not apply under  
chapter 4. The exemptions from withholding or taxation  
provided for under chapter 3 are not applicable when  
determining whether withholding applies under chapter 4.  
For exceptions applicable to the definition of a  
withholdable payment, see Regulations section  
1.1473-1(a)(4) (exempting, for example, certain  
nonfinancial payments).  
The beneficial owner of income paid to a foreign estate  
is the estate itself.  
These beneficial owner rules apply primarily for  
purposes of withholding under sections 1441 and 1442.  
The rules also generally apply for purposes of section  
1446, with a few exceptions. See Regulations section  
1.1446-1 for instances where the documentation  
requirements of sections 1441 and 1442 differ from  
section 1446.  
For purposes of completing Form W-8EXP, a foreign  
partnership that is a withholding qualified holder under  
section 1445 should be identified as the beneficial owner.  
Chapter 3. Chapter 3 means chapter 3 of the Internal  
Revenue Code (Withholding of Tax on Nonresident Aliens  
and Foreign Corporations) under sections 1441 through  
1464.  
Chapter 4. Chapter 4 means chapter 4 of the Internal  
Revenue Code (Taxes to Enforce Reporting on Certain  
Foreign Accounts). Chapter 4 contains sections 1471  
through 1474.  
Commercial activities. For purposes of chapter 4,  
commercial activities are financial activities of a type  
engaged in by an insurance company, custodial institution,  
or depository institution (including the act of accepting  
deposits). An exempt beneficial owner will not be  
considered exempt for chapter 4 purposes with respect to  
payments derived from an obligation held in connection  
with a commercial financial activity. See Regulations  
section 1.1471-6(h), including limitations on the scope of  
a commercial financial activity. For purposes of chapter 3,  
commercial activities are described in Temporary  
Regulations section 1.892-4T.  
Beneficial owner. For payments other than those for  
which a reduced rate of, or exemption from, withholding is  
claimed under an income tax treaty, the beneficial owner  
of income is generally the person who is required under  
U.S. tax principles to include the payment in gross income  
on a tax return. A person is not a beneficial owner of  
income, however, to the extent that person is receiving the  
income as a nominee, agent, or custodian, or to the extent  
the person is a conduit whose participation in a  
Controlled commercial entity. A controlled commercial  
entity is an entity engaged in commercial activities  
described in Temporary Regulations section 1.892-4T  
(whether conducted within or outside the United States) if  
the foreign government holds (directly or indirectly):  
transaction is disregarded. In the case of amounts paid  
that do not constitute income, beneficial ownership is  
determined as if the payment were income.  
Any interest in the entity which (by value or voting  
power) is 50% or more of the total of such interests in the  
entity, or  
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Instructions for Form W-8EXP (Rev. 10-2023)  
 
A sufficient interest (by value or voting power) or any  
of International Settlements is treated as though it were a  
foreign central bank of issue.  
A foreign central bank of issue must provide Form  
W-8EXP to establish eligibility for exemption from  
withholding for payments exempt from tax under either  
section 892 or section 895.  
other interest in the entity which provides the foreign  
government with effective practical control of the entity.  
For this purpose, an entity means a corporation, a  
partnership, a trust (including a pension trust), and an  
estate. A partnership’s commercial activities are  
attributable to its general and, subject to Proposed  
Regulations section 1.892-5(a)(5), limited partners for  
purposes of determining whether the partner is a  
controlled commercial entity for purposes of section 892.  
The partnership’s commercial activities will result in the  
partnership having to withhold tax under section 1446 on  
commercial income that is the ECTI allocable to a foreign  
government partner.  
Foreign financial institution (FFI). An FFI generally  
means a foreign entity that is a financial institution.  
Foreign person. A foreign person includes a nonresident  
alien individual, foreign corporation, foreign partnership,  
foreign trust, foreign estate, foreign government,  
international organization, foreign central bank of issue,  
foreign tax-exempt organization, foreign private  
foundation, or government of a U.S. territory, and any  
other person that is not a U.S. person. It also includes a  
foreign branch or office of a U.S. financial institution or  
U.S. clearing organization if the foreign branch is a  
qualified intermediary. Generally, a payment to a U.S.  
branch of a foreign person is a payment to a foreign  
person.  
Foreign government. For chapter 3 purposes, a foreign  
government includes only the integral parts or controlled  
entities of a foreign sovereign as defined in Temporary  
Regulations section 1.892-2T. See Regulations section  
1.1471-6(b) for definitions of integral part and controlled  
entity that apply for chapter 4 purposes.  
An integral part of a foreign sovereign, in general, is any  
person, body of persons, organization, agency, bureau,  
fund, instrumentality, or other body, however designated,  
that constitutes a governing authority of a foreign country.  
The net earnings of the governing authority must be  
credited to its own account or to other accounts of the  
foreign sovereign, with no portion benefiting any private  
person.  
Note. A foreign central bank of issue will be treated as a  
controlled commercial entity only if it engages in  
commercial activities within the United States.  
Chapter 4 status. The term chapter 4 status means a  
person’s status as a U.S. person, specified U.S. person,  
restricted distributor, exempt beneficial owner,  
nonparticipating FFI, territory financial institution,  
excepted nonfinancial foreign entity (NFFE), or passive  
NFFE. See Regulations section 1.1471-1(b) for the  
definitions of these terms.  
Deemed-compliant FFI. Under section 1471(b)(2),  
certain FFIs are deemed to comply with the regulations  
under chapter 4 without the need to enter into an FFI  
agreement with the IRS. However, certain  
deemed-compliant FFIs are required to register with the  
IRS and obtain a Global Intermediary Identification  
Number (GIIN). These FFIs are referred to as registered  
deemed-compliant FFIs. See Regulations section  
1.1471-5(f).  
A controlled entity of a foreign sovereign is an entity  
that is separate in form from the foreign sovereign or  
otherwise constitutes a separate juridical entity only if:  
Exempt beneficial owner. An exempt beneficial owner  
means a person that is described in Regulations section  
1.1471-6 and includes a foreign government, a political  
subdivision of a foreign government, a wholly owned  
instrumentality or agency of a foreign government or  
governments, an international organization, a wholly  
owned agency or instrumentality of an international  
organization, a foreign central bank of issue, a  
It is wholly owned and controlled by the foreign  
sovereign directly or indirectly through one or more  
controlled entities.  
It is organized under the laws of the foreign sovereign  
by which it is owned.  
Its net earnings are credited to its own account or to  
government of a U.S. territory, certain retirement funds,  
and certain entities wholly owned by one or more exempt  
beneficial owners. In addition, an exempt beneficial owner  
includes any person treated as an exempt beneficial  
owner under an applicable Model 1 IGA or Model 2 IGA  
(defined later).  
Financial institution. A financial institution generally  
means an entity that is a depository institution, custodial  
institution, investment entity, or an insurance company (or  
holding company of an insurance company) that issues  
cash value insurance or annuity contracts. See  
Regulations section 1.1471-5(e).  
Foreign central bank of issue. A foreign central bank of  
issue is a bank that is by law or government sanction the  
principal authority, other than the government itself, to  
issue instruments intended to circulate as currency. Such  
a bank is generally the custodian of the banking reserves  
of the country under whose law it is organized. The Bank  
other accounts of the foreign sovereign, with no portion of  
its income inuring to the benefit of any private person.  
Its assets vest in the foreign sovereign upon dissolution.  
A controlled entity of a foreign sovereign also includes  
a pension trust defined in Temporary Regulations section  
1.892-2T(c) and may include a foreign central bank of  
issue to the extent that it is wholly owned by a foreign  
sovereign.  
A foreign government must provide Form W-8EXP to  
establish eligibility for exemption from withholding for  
payments exempt from tax under section 892 or for  
purposes of establishing its status as an exempt beneficial  
owner.  
Intergovernmental agreement (IGA). An IGA means a  
Model 1 IGA or a Model 2 IGA. For a list of jurisdictions  
treated as having in effect a Model 1 or Model 2 IGA, see  
Instructions for Form W-8EXP (Rev. 10-2023)  
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the list of jurisdictions at home.treasury.gov/Policy-Issues/  
pension fund) or a qualified controlled entity that satisfies  
the requirements of either Regulations section  
1.897(l)-1(d)(2) or Regulations section 1.897(l)-1(d)(3).  
A Model 1 IGA means an agreement between the  
United States or the Treasury Department and a foreign  
government or one or more agencies to implement FATCA  
through reporting by FFIs to such foreign government or  
agency thereof, followed by automatic exchange of the  
reported information with the IRS. An FFI in a Model 1 IGA  
jurisdiction that performs account reporting to the  
jurisdiction’s government is referred to as a reporting  
Model 1 FFI.  
A Model 2 IGA means an agreement or arrangement  
between the United States or the Treasury Department  
and a foreign government or one or more agencies to  
implement FATCA through reporting by FFIs directly to the  
IRS in accordance with the requirements of an FFI  
agreement, supplemented by the exchange of information  
between such foreign government or agency thereof and  
the IRS. An FFI in a Model 2 IGA jurisdiction that has  
entered into an FFI agreement with respect to a branch is  
a participating FFI, but may be referred to as a reporting  
Model 2 FFI.  
International organization. For purposes of chapter 3,  
an international organization is any public international  
organization entitled to enjoy privileges, exemptions, and  
immunities as an international organization under the  
International Organizations Immunities Act (22 U.S.C.  
288-288(f)). In general, to qualify as an international  
organization, the United States must participate in the  
organization pursuant to a treaty or under the authority of  
an Act of Congress authorizing such participation.  
Qualified investment entity. A qualified investment  
entity is a person described in section 897(h)(4).  
Specified U.S. person. A specified U.S. person is any  
U.S. person other than a person identified in Regulations  
section 1.1473-1(c).  
Substantial U.S. owner. A substantial U.S. owner (as  
described in Regulations section 1.1473-1(b)) means any  
specified U.S. person that:  
Owns, directly or indirectly, more than 10% (by vote or  
value) of the stock of any foreign corporation;  
Owns, directly or indirectly, more than 10% of the profits  
interests or capital interests in a foreign partnership;  
Is treated as an owner of any portion of a foreign trust  
under sections 671 through 679; or  
Holds, directly or indirectly, more than a 10% beneficial  
interest in a trust.  
Territory financial institution. The term territory  
financial institution means a financial institution that is  
incorporated or organized under the laws of any U.S.  
territory. However, an investment entity that is not also a  
depository institution, custodial institution, or specified  
insurance company is not a territory financial institution.  
Withholdable payment. The term withholdable payment  
means an amount subject to withholding for purposes of  
chapter 4 as described in Amounts subject to withholding,  
earlier. Also see Regulations section 1.1473-1(a) for the  
definition of withholdable payment.  
Withholding agent. Any person, U.S. or foreign, that has  
control, receipt, custody, disposal, or payment of U.S.  
source FDAP income subject to chapter 3 or 4 withholding  
is a withholding agent. The withholding agent may be an  
individual, corporation, partnership, trust, association, or  
any other entity, including (but not limited to) any foreign  
intermediary, foreign partnership, and U.S. branches of  
certain foreign banks and insurance companies.  
Any organization that qualifies as an international  
organization under chapter 3 also qualifies as an  
international organization under chapter 4.  
For purposes of chapter 4, an international organization  
also includes any intergovernmental or supranational  
organization that is comprised primarily of foreign  
governments, that is recognized as an intergovernmental  
or supranational organization under a foreign law similar to  
22 U.S.C. 288-288(f) or that has in effect a headquarters  
agreement with a foreign government, and whose income  
does not inure to the benefit of private persons.  
Withholding qualified holder. The term withholding  
qualified holder means a qualified holder (under  
Regulations section 1.897(l)-1(d)), and a foreign  
partnership all of the interests of which are held by  
qualified holders (under Regulations section  
Participating FFI. A participating FFI is an FFI that has  
agreed to comply with the terms of an FFI agreement with  
respect to all branches of the FFI, other than a branch that  
is a reporting Model 1 FFI or a U.S. branch. The term  
participating FFI also includes a reporting Model 2 FFI and  
a QI branch of a U.S. financial institution, unless such  
branch is a reporting Model 1 FFI.  
Qualified controlled entity. A qualified controlled entity  
is a trust or corporation created or organized under the  
laws of a foreign jurisdiction, all of the interests of which  
are held by one or more qualified foreign pension funds  
directly or indirectly through one or more qualified  
controlled entities.  
1.897(l)-1(d)), including through one or more partnerships.  
Specific Instructions  
Part I — Identification of Beneficial  
Owner  
Before completing Part I, complete the Worksheet for  
Foreign Governments, International Organizations, and  
Foreign Central Banks of Issue, later, to determine  
whether amounts received are or will be exempt from U.S.  
tax under section 892 or 895 and exempt from withholding  
under sections 1441 and 1442. Use the results of this  
worksheet to check the appropriate box on line 3 and in  
Part II. Do not give the worksheet to the withholding agent.  
Instead, keep it for your records.  
Qualified foreign pension fund. A qualified foreign  
pension fund is a person that satisfies the requirements of  
section 897(l) and Regulations section 1.897(l)-1.  
Qualified holder. A qualified holder is a qualified foreign  
pension fund (including a part of a qualified foreign  
Line 1. Enter the full name of the organization.  
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Instructions for Form W-8EXP (Rev. 10-2023)  
     
Line 2. Enter the country under the laws of which the  
foreign government or other foreign organization was  
created, incorporated, organized, or governed.  
Line 5. The permanent address of a foreign government,  
international organization, or foreign central bank of issue  
is where it maintains its principal office. For all other  
organizations, the permanent address is the address in  
the country where the organization claims to be a resident  
for tax purposes. Do not show the address of a financial  
institution, a post office box, or an address used solely for  
mailing purposes unless such address is the only  
Line 3. Check the one box that applies (unless you are  
also documenting yourself as a withholding qualified  
holder under section 1445). A foreign central bank of  
issue (wholly owned by a foreign sovereign) should check  
the “Foreign government” box. If you are a foreign private  
foundation, you should check the “Foreign private  
foundation” box rather than the “Foreign tax-exempt  
organization” box. If you are providing this form to claim an  
exemption to withholding under section 1445 as a  
qualified foreign pension fund that is a qualified holder  
(within the meaning of Regulations section 1.897(l)-1(e)  
(11)) or as a foreign partnership, all of the interests of  
which are held by qualified holders, including through one  
or more partnerships, you should check the “Withholding  
qualified holder under section 1445” box. See Regulations  
section 1.1445-1(g)(11). For purposes of completing this  
Form W-8EXP, a foreign partnership that is a withholding  
qualified holder should identify itself as the beneficial  
owner.  
permanent address you use and it appears as your  
registered address in your organizational documents.  
Line 6. Enter the mailing address only if it is different from  
the address shown on line 5.  
Line 7. A U.S. taxpayer identification number (TIN)  
means an employer identification number (EIN). A U.S.  
TIN is generally required if you are claiming an exemption  
or reduced rate of withholding based solely on your claim  
of tax-exempt status under section 501(c) or private  
foundation status. Use Form SS-4 to obtain an EIN.  
Line 8a. If the organization has registered with the IRS as  
a participating FFI (including a reporting Model 2 FFI),  
registered deemed-compliant FFI (including a reporting  
Model 1 FFI), or a direct reporting NFFE, provide your  
GIIN. For payments made prior to January 1, 2015, a  
Form W-8EXP provided by a reporting Model 1 FFI need  
not contain a GIIN. For payments made prior to January 1,  
2016, a sponsored direct reporting NFFE may provide the  
GIIN of its sponsoring entity.  
If you are providing this form to document yourself as a  
withholding qualified holder under section 1445 and for  
purposes of sections 1441-1443 or section 1446, check  
the "Withholding qualified holder under section 1445" box  
and the one box that otherwise applies to your status. In  
all other cases, only one box should be checked.  
Line 8b. If you are providing this Form W-8EXP to  
document yourself as an account holder (as defined in  
Regulations section 1.1471-5(a)(3)) with respect to a  
financial account (as defined in Regulations section  
1.1471-5(b)) that you hold at a U.S. office of a financial  
institution (including a U.S. branch of an FFI) and you  
receive U.S. source income reportable on a Form 1042-S  
associated with this form, you must provide on line 8b the  
foreign TIN (FTIN) issued to you by the jurisdiction in  
which you are a tax resident identified on line 5 unless:  
Line 4. Check the one box that applies to your chapter 4  
status (if necessary). You are required to provide a  
chapter 4 status if you are the payee of a withholdable  
payment or hold an account with an FFI requesting this  
form. See Regulations section 1.1471-3(a) for the  
definition of a payee for purposes of chapter 4. By  
checking a box on this line, you are representing that you  
qualify for this classification and, if you are claiming a  
status as an exempt beneficial owner, that you are the  
beneficial owner of the payments to which this form  
relates for purposes of chapter 4.  
Your jurisdiction of residence is identified on the List of  
Jurisdictions That Do Not Issue Foreign TINs at IRS.gov/  
For certain chapter 4 statuses, you are required to  
complete an additional line on this form certifying  
that you meet the conditions of the status  
TIP  
You properly identified yourself as a foreign  
indicated on line 4 (as defined under Regulations section  
1.1471-5 or 1.1471-6 or an applicable IGA). Make sure  
you complete the required portion of this form before  
signing and providing it to the withholding agent.  
government, foreign central bank of issue, international  
organization, or government of a U.S. territory on line 3.  
If you are providing this form to document a financial  
account described above but you do not enter an FTIN on  
line 8b, and you are not a foreign government, foreign  
central bank of issue, international organization, or  
government of a U.S. territory, you must provide the  
withholding agent with an explanation of why you have not  
been issued a TIN (including if the jurisdiction does not  
issue TINs). For this purpose, an explanation is a  
statement that you are not legally required to obtain a TIN  
in your jurisdiction of tax residence. The explanation may  
be written on line 8b, in the margins of the form, or on a  
separate attached statement associated with the form. If  
you are writing the explanation on line 8b, you may  
shorten it to “not legally required.Do not write “not  
applicable.”  
If you do not certify as to your chapter 4 status,  
this Form W-8EXP will not be valid for purposes of  
!
CAUTION  
chapter 4 if you receive a withholdable payment at  
any time in the future. For example, if you do not certify as  
to your chapter 4 status because the only payments you  
receive from the withholding agent are with respect to  
grandfathered obligations described in Regulations  
section 1.1471-2(b), then you will be required to resubmit  
Form W-8EXP and certify to your chapter 4 status if you  
receive a withholdable payment in the future. You may  
consider certifying to your chapter 4 status even if not  
required in order to avoid resubmitting Form W-8EXP to  
the withholding agent. See Expiration of Form W-8EXP,  
earlier.  
Instructions for Form W-8EXP (Rev. 10-2023)  
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If you are providing this form to certify your status as a  
withholding qualified holder under section 1445 and did  
not provide an EIN on line 7, provide your FTIN on line 8b.  
Line 9. This line may be used by the filer of Form  
W-8EXP or by the withholding agent to whom it is  
provided to include any referencing information that is  
necessary or useful to the withholding agent in carrying  
out its obligations. For example, a filer may use line 9 to  
include the name and number of the account for which the  
filer is providing the form.  
officers. The affidavit must include information on your  
financial support if you are claiming public charity status  
under sections 509(a)(1) and 170(b)(1)(A)(vi) or section  
Your Organization, for information on determining whether  
you are a public charity or private foundation.  
In lieu of providing information in an affidavit concerning  
your operations, support, and financial information (when  
applicable), you may satisfy this requirement by  
referencing the opinion of U.S. counsel provided in  
accordance with Box 13b of these instructions when the  
opinion:  
Part II — Qualification Statement for  
Chapter 3 Status  
Concludes that you qualify under section 509(a)(1), (2),  
(3), or (4); and  
Meets the requirements of current written advice  
You are not required to complete a chapter 3  
rendered for a public charity equivalency determination in  
qualification statement if you are submitting this  
form to document your chapter 4 status and are  
TIP  
not receiving a payment that is subject to withholding  
under chapter 3. However, in such a case, you may also  
provide Form W-8BEN-E to document your chapter 4  
status.  
If the opinion of U.S. counsel satisfies the above  
requirements, you may check this box despite that  
it references only the affidavit on this form.  
TIP  
An opinion of counsel or affidavit must be renewed if  
there has been a change in facts relevant to your  
tax-exempt status under section 501(c) or your public  
charity status under section 509.  
Line 10. All foreign governments claiming the  
applicability of section 892 must check box 10a as well as  
box 10b or box 10c, whichever applies. Enter the name of  
the foreign sovereign’s country on line 10b (if the entity is  
an integral part of a foreign government) or on line 10c (if  
the entity is a controlled entity of a foreign government). A  
foreign central bank of issue (wholly owned by a foreign  
sovereign) should check box 10c.  
Box 13d. Check this box if you are a section 501(c)(3)  
organization and you are a private foundation described in  
section 509.  
Line 14. Check this box if you are a government of a U.S.  
territory. By checking this box you are certifying to the  
statements made in line 14.  
Line 15. Check the applicable box if you are a  
withholding qualified holder. By checking one of these  
boxes, you are certifying to the statement made in either  
line 15a or line 15b, as applicable.  
Line 11. Check this box if you are an international  
organization. By checking this box, you are certifying to all  
the statements made in line 11.  
Line 12. Check this box if you are a foreign central bank  
of issue for purposes of chapter 3 (see definitions) not  
wholly owned by a foreign sovereign. By checking this  
box, you are certifying to all the statements made in  
line 12.  
Line 13. If you are a foreign tax-exempt organization, you  
must attach a statement setting forth any income that is  
includible under section 512 in computing your unrelated  
business taxable income.  
Box 13a. Check this box if you have been issued a  
determination letter by the IRS. Enter the date of the IRS  
determination letter.  
Box 13b. Check this box if you do not have an IRS  
determination letter, but are providing an opinion of U.S.  
counsel concluding that you are an organization described  
in section 501(c).  
Box 13c. If you are a section 501(c)(3) organization,  
check this box if you are not a private foundation. You  
must attach to the withholding certificate an affidavit  
setting forth sufficient facts concerning your operations  
and support to enable the IRS to determine that you would  
be likely to qualify as an organization described in section  
509(a)(1), (2), (3), or (4) rather than as a private  
foundation.  
Part III — Qualification Statement for  
Chapter 4 Status  
You are not required to complete a chapter 4  
qualification statement if you are not the payee of  
a withholdable payment or are not an  
TIP  
accountholder holding an account with an FFI requesting  
this form.  
Line 16. Check this box to indicate that you are treated  
as a nonreporting FFI under an applicable IGA (and as  
defined in the IGA). You must identify the applicable IGA  
by entering the name of the jurisdiction that has the  
applicable IGA in effect with the United States. You must  
also provide the withholding agent with the class of entity  
described in Annex II of the IGA applicable to your status.  
If you are an FFI treated as a registered  
deemed-compliant FFI under an applicable Model 2 IGA,  
you must provide your GIIN in the space provided.  
Line 17. Check this box if you are a territory financial  
institution. By checking this box, you are certifying to the  
statement in line 17.  
Line 18. Check this box if you are a foreign government,  
government of a U.S. territory, or foreign central bank of  
issue as defined for purposes of chapter 4 (see  
The affidavit must be based on information from your  
latest accounting year, identify the type of section 501(c)  
(3) organization (for example, charitable, religious,  
educational), and be signed by one of your principal  
-8-  
Instructions for Form W-8EXP (Rev. 10-2023)  
Regulations section 1.1471-6). By checking this box, you  
are certifying to the statement made in line 18.  
Line 19. Check the applicable box if you are an exempt  
retirement plan of a foreign government as defined for  
purposes of chapter 4. By checking one of these boxes,  
you are certifying to the statement made in either line 19a  
or line 19b, as applicable.  
Line 20. Check this box if you are a 501(c) organization  
other than an insurance company described in section  
501(c)(15). By checking this box, you are certifying to the  
statement made in line 20.  
indicate that the form was electronically signed by a  
person authorized to do so (for example, with a time and  
date stamp and statement that the form has been  
electronically signed). Simply typing your name into the  
signature line is not an electronic signature.  
Paperwork Reduction Act Notice. We ask for the  
information on this form to carry out the Internal Revenue  
laws of the United States. You are required to provide the  
information. We need it to ensure that you are complying  
with these laws and to allow us to figure and collect the  
right amount of tax.  
Line 21. Check box 21a if you are passive NFFE. If you  
do not have any substantial U.S. owners, check box 21b. If  
you have any substantial U.S. owners, you must provide a  
statement with the information set forth on line 21c.  
Line 22. Check this box if you are a sponsored direct  
reporting NFFE. Provide the name of your sponsoring  
entity in the space provided. By checking this box, you are  
certifying to the statement made in line 22.  
You are not required to provide the information  
requested on a form that is subject to the Paperwork  
Reduction Act unless the form displays a valid OMB  
control number. Books or records relating to a form or its  
instructions must be retained as long as their contents  
may become material in the administration of any Internal  
Revenue law. Generally, tax returns and return information  
are confidential, as required by section 6103.  
The time needed to complete and file this form will vary  
depending on individual circumstances. The estimated  
average time is: Recordkeeping, 7hr., 10min.; Learning  
about the law or the form, 5 hr., 42 min.; and Preparing  
and providing the form, 8 hr., 27 min.  
Part IV — Certification  
Form W-8EXP must be signed and dated by an authorized  
official of the foreign government, international  
organization, foreign central bank of issue, foreign  
tax-exempt organization, foreign private foundation,  
government of a U.S. territory, or withholding qualified  
holder, as appropriate. By signing Form W-8EXP, the  
authorized representative, officer, or agent also agrees to  
provide a new form within 30 days following a change in  
circumstances that makes any certification made on the  
form incorrect (unless no future payments will be made to  
the organization by the withholding agent). The authorized  
representative, officer, or agent must also check the box to  
certify that he or she has the capacity to sign for the  
organization.  
If you have comments concerning the accuracy of  
these time estimates or suggestions for making this form  
simpler, we would be happy to hear from you. You can  
send us comments from IRS.gov/FormComments. You  
can write to the Internal Revenue Service, Tax Forms and  
Publications, 1111 Constitution Ave. NW, IR-6526,  
Washington, DC 20224. Do not send Form W-8EXP to  
this office. Instead, give it to your withholding agent.  
A withholding agent may allow you to provide this form  
with an electronic signature. The electronic signature must  
Instructions for Form W-8EXP (Rev. 10-2023)  
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WORKSHEET FOR FOREIGN GOVERNMENTS,  
INTERNATIONAL ORGANIZATIONS, AND FOREIGN  
CENTRAL BANKS OF ISSUE  
Keep for Your Records  
(Do not give to the withholding agent.)  
Complete this worksheet to determine whether amounts received are or will be exempt from U. S. tax under section 892 or  
section 895 and exempt from withholding under sections 1441 and 1442.  
Foreign governments and foreign central banks of issue, start with question 1.  
International organizations, go directly to question 6.  
FOREIGN GOVERNMENT  
Yes  
No  
1 a Is the foreign government an integral part of a foreign sovereign (see Definitions)? . . . . . . . . . . . . . . . . .  
(If “Yes,go to question 4. If “No,” answer question 1b.)  
b
Is the foreign government a controlled entity of a foreign sovereign (see Definitions)? . . . . . . . . . . . . . .  
(If “Yes,answer question 2a. If “No,” go to question 7a.)  
2 a Is the controlled entity a foreign central bank of issue (see Definitions)? . . . . . . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,answer question 2b. If “No,” go to question 3.)  
b
Is the foreign central bank of issue engaged in commercial activities within the United States? . . . . . . .  
(If “Yes,answer question 7a. If “No,” go to question 4.)  
3
4
Is the controlled entity engaged in commercial activities anywhere in the world? . . . . . . . . . . . . . . . . . . . .  
(If “Yes,income is not exempt from tax under section 892 and may be subject to withholding. Do not  
complete Form W-8EXP for such income. Instead, complete Form W-8BEN-E or W-8ECI. If “No,”  
answer question 4.)  
Does the foreign government or foreign central bank of issue (wholly owned by the foreign sovereign)  
receive income directly or indirectly from any controlled commercial entities or income derived from the  
disposition of any interest in a controlled commercial entity (see Definitions)? . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,income is not exempt from tax under section 892 and may be subject to withholding. Do not  
complete Form W-8EXP for such income. Instead, complete Form W-8BEN-E or W-8ECI. If “No,”  
answer question 5.)  
5
Is any of the income received by the foreign government or foreign central bank of issue (wholly owned  
by the foreign sovereign) from sources other than investments in the United States in stocks, bonds,  
other domestic securities (as defined in Temporary Regulations section 1.892-3T(a)(3)), financial  
instruments held in the execution of governmental financial or monetary policy (as defined in  
Temporary Regulations section 1.892-3T(a)(4) and (a)(5)), or interest on deposits in banks in the  
United States? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,income is not exempt from tax under section 892 and may be subject to withholding. Do not  
complete Form W-8EXP for such income. Instead, complete Form W-8BEN-E or W-8ECI. If “No,”  
check the appropriate box on line 10 of Form W-8EXP.)  
INTERNATIONAL ORGANIZATION  
Yes  
Yes  
No  
No  
6
Is the international organization an organization in which the United States participates pursuant to any  
treaty or under an Act of Congress authorizing such participation and to which the President of the  
United States has issued an Executive Order entitling the organization to enjoy the privileges,  
exemptions, and immunities provided under the International Organization Immunities Act (22 U.S.C.  
288, 288e, 288f)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,check the box on line 11 of Form W-8EXP. If “No,” income may be subject to withholding. Do  
not complete this form for such income. Instead, complete Form W-8BEN-E or W-8ECI.)  
FOREIGN CENTRAL BANK OF ISSUE  
7 a Is the entity, whether wholly or partially owned by the foreign sovereign, a foreign central bank of  
issue? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,answer question 7b. If “No,” income is not exempt from tax under section 895 and may be  
subject to withholding. Do not complete Form W-8EXP for such income. Instead, complete Form  
W-8BEN-E or W-8ECI.)  
b
c
Is the income received by the foreign central bank of issue from sources other than obligations of the  
United States (or any agency or instrumentality thereof) or from interest on deposits with persons  
carrying on the banking business? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,income is not exempt from tax under section 895 and may be subject to withholding. Do not  
complete Form W-8EXP for such income. Instead, complete Form W-8BEN-E or W-8ECI. If “No,”  
answer question 7c.)  
Are the obligations of the United States (or any agency or instrumentality thereof) or bank deposits  
owned by the foreign central bank of issue held for, or used in connection with, the conduct of  
commercial banking functions or other commercial activities by the foreign central bank of  
issue? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
(If “Yes,income is not exempt from tax under section 895 and may be subject to withholding. Do not  
complete Form W-8EXP for such income. Instead, complete Form W-8BEN-E or W-8ECI. If “No,”  
check the box on line 12 of Form W-8EXP.)  
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