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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           Withholding rules. Foreign persons are subject to U.S. 
unless otherwise noted.                                       tax at a 30% rate on payments they receive from U.S. 
                                                              sources that consist of:
Future Developments                                           • Interest (including certain original issue discount (OID));
                                                              • Dividends;
For the latest information about developments related to      • Rents;
Form W-8EXP and its instructions, such as legislation         • Royalties;
enacted after they were published, go to IRS.gov/             • Premiums;
FormW8EXP.                                                    • 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 
                                                              or
provide additional background on the withholding regimes 
                                                              • Other fixed or determinable annual or periodical gains, 
that may apply to payments to foreign entities and the 
                                                              profits, or income.
exemptions to withholding that may be claimed with Form 
W-8EXP. These revisions are not intended to be                  This tax is imposed on the gross amount paid and is 
substantive changes.                                          generally collected by withholding under section 1441 or 
                                                              1442 on that amount. Certain payments made to foreign 
Qualified foreign pension funds. These instructions           private foundations are instead subject to tax at a 4% rate 
have been updated to reflect final regulations published in   under section 1443.
December 2022 (87 FR 80042) regarding qualified foreign 
                                                                Under chapter 4, withholdable payments made to a 
pension funds and claiming an exemption to withholding 
                                                              foreign entity are generally subject to withholding at a 30% 
under section 1445.
                                                              rate unless the entity has established an exemption to 
Non-private foundation status. The instructions to            withholding based on a valid chapter 4 status.
line 13c have been updated for revisions to the supporting      Gain or loss of a foreign person on the disposition of a 
information required for an entity qualifying under section   U.S. real property interest (USRPI) is taken into account 
501(c)(3) to represent that it is not a foreign private       as if the gain or loss is effectively connected with a U.S. 
foundation. These revisions generally relate to               trade or business under section 897. The transferee is 
modifications to Rev. Proc. 92-94, 1992-2 C.B. 507            generally required to withhold tax from the amount 
(previously referenced in these instructions) that were       realized under section 1445. Certain distributions by 
made in Rev. Proc. 2017-53, 2017-40 I.R.B. 263.               qualified investment entities (QIEs) that are attributable to 
                                                              the disposition of USRPIs are also subject to withholding 
General Instructions                                          under section 1445. Gain or loss of a foreign person that 
                                                              is a qualified holder (as defined in Regulations section 
Purpose of Form                                               1.897(l)-1(d)) on the disposition of a USRPI or on a 
If you receive certain types of income, you must provide      portion of a distribution from a qualified investment entity 
Form W-8EXP to:                                               that is attributable to the disposition of USRPIs is exempt 
• Establish that you are not a U.S. person;                   from tax under section 897 and from withholding under 
• Claim that you are the beneficial owner of the income       section 1445. The amount realized by a foreign 
for which Form W-8EXP is given; and                           partnership all the interests of which are held by qualified 
• Claim a reduced rate of, or exemption from, withholding     holders (a withholding qualified holder as defined in 
as a foreign government, international organization,          Regulations section 1.1445-1(g)(11)) on the disposition of 
foreign central bank of issue, foreign tax-exempt             a USRPI or a distribution from a QIE that is attributable to 
organization, foreign private foundation, or a government     the disposition of USRPIs is exempt from withholding 
of a U.S. territory.                                          under section 1445.
  In addition, a withholding qualified holder under section     Foreign persons are also subject to tax at graduated 
1445 may use a Form W-8EXP to establish that it is            rates on income they earn that is considered effectively 
treated as a non-foreign person and claim an exemption to     connected with a U.S. trade or business. If a foreign 
withholding pursuant to section 897(l) (relating to qualified person holds an interest in a partnership that conducts a 
foreign pension funds).                                       U.S. trade or business, the foreign person is considered to 
                                                              be engaged in a U.S. trade or business. The partnership is 

Nov 7, 2023                                             Cat. No. 25903G

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required to withhold tax under section 1446(a) on the         foreign government, international organization, foreign 
foreign person's allocable share of the partnership's         central bank of issue, foreign tax-exempt organization, 
effectively connected taxable income (ECTI). A foreign        foreign private foundation, or government of a U.S. 
person that directly or indirectly disposes of an interest in territory must provide a Form W-8EXP to a withholding 
a partnership that conducts a U.S. trade or business may      agent or payer with all necessary documentation. The 
have gain treated as effectively connected income under       withholding agent or payer of the income may rely on a 
section 864(c)(8). Under section 1446(f), the transferee      valid Form W-8EXP to treat the payment, credit, or 
purchasing that partnership interest is generally required    allocation associated with the Form W-8EXP as being 
to withhold a tax equal to 10% of the amount realized.        made to a foreign government, international organization, 
                                                              foreign central bank of issue, foreign tax-exempt 
Exemptions to withholding. In general, payments to a 
                                                              organization, foreign private foundation, or government of 
foreign government (including a foreign central bank of 
                                                              a U.S. territory that is exempt from withholding at the 30% 
issue wholly owned by a foreign sovereign) from 
                                                              rate (or, where appropriate, subject to withholding at a 4% 
investments in the United States in stocks, bonds, other 
                                                              rate).
domestic securities, financial instruments held in the 
execution of governmental financial or monetary policy,             For purposes of section 1445, a withholding qualified 
and interest on deposits in banks in the United States are    holder may establish an exemption from tax under section 
exempt from tax under section 892 and exempt from             897 by providing a Form W-8EXP to a withholding agent 
withholding under sections 1441 and 1442. Payments            or transferee. A withholding qualified holder is not exempt 
other than those described above, including income            from withholding under section 1441 or 1442 by virtue of 
derived in the United States from the conduct of a            its status as a withholding qualified holder.
commercial activity, income received from a controlled 
                                                                    For purposes of section 1446(a), a partner may provide 
commercial entity (including gain from the disposition of 
                                                              a Form W-8EXP to reduce its ECTI subject to withholding 
any interest in a controlled commercial entity), and income 
                                                              if it is a:
received by a controlled commercial entity, do not qualify 
for exemption from tax under section 892 or exemption             • Foreign tax-exempt organization (under section 501(c)) 
                                                              receiving an allocable share of income that is not 
from withholding under sections 1441 and 1442. See 
                                                              includible under sections 512 and 513, or
Temporary Regulations section 1.892-3T. In addition, 
certain distributions to a foreign government from a real         • Qualified holder under section 1445 receiving an 
                                                              allocable share of income subject to section 897. See 
estate investment trust (REIT) may not be eligible for relief 
                                                              Regulations section 1.1446-1(c)(2)(ii)(G).
from withholding and may be subject to withholding at 
21% (35% for distributions made before January 1, 2018)             In addition chapter 4 requires withholding agents to 
of the gain realized. For the definition of “commercial       identify the chapter 4 status of payees receiving 
activities,” see Temporary Regulations section 1.892-4T.      withholdable payments to determine whether withholding 
In general, payments to an international organization         applies under chapter 4. Under chapter 4, certain foreign 
from investment in the United States in stocks, bonds and     governments, foreign central banks, international 
other domestic securities, interest on deposits in banks in   organizations, and foreign entities described in section 
the United States, and payments from any other source         501(c) (other than an insurance company described in 
within the United States are exempt from tax under            section 501(c)(15)) are not subject to withholding under 
section 892 and exempt from withholding under sections        chapter 4. A withholding agent may request this Form 
1441 and 1442. See Temporary Regulations section              W-8EXP to establish your chapter 4 status and avoid 
1.892-6T. Payments to a foreign central bank of issue         withholding.
(whether or not wholly owned by a foreign sovereign) or to          Chapter 4 also requires participating foreign financial 
the Bank for International Settlements from obligations of    institutions (FFIs) and certain registered 
the United States or of any agency or instrumentality         deemed-compliant FFIs to document entity account 
thereof, or from interest on deposits with persons carrying   holders in order to determine their chapter 4 status 
on the banking business, are also generally exempt from       regardless of whether withholding applies to any 
tax under section 895 and exempt from withholding under       payments made to the entities. If you maintain an account 
sections 1441 and 1442. In addition, payments to a            with an FFI and have a chapter 4 status shown in Part I, 
foreign central bank of issue from bankers’ acceptances       line 4 of this form, provide this Form W-8EXP when 
are exempt from tax under section 871(i)(2)(C) and            requested by the FFI in order to document your chapter 4 
exempt from withholding under sections 1441 and 1442.         status.
Payments to a foreign tax-exempt organization of              Additional information. For additional information and 
certain types of U.S. source income are also generally        instructions for the withholding agent, see the Instructions 
exempt from tax and exempt from withholding. Gross            for the Requester of Forms W–8 BEN, W–8 BEN–E, W–8 
investment income of a foreign private foundation,            ECI, W–8 EXP, and W–8 IMY.
however, is subject to withholding under section 1443(b) 
at a rate of 4%.                                              Who must provide Form W-8EXP. You must give Form 
                                                              W-8EXP to the withholding agent or payer if you are:
Payments to a government of a territory of the United             • A foreign government, international organization, 
States are generally exempt from tax and withholding          foreign central bank of issue, foreign tax-exempt 
under section 115(2).                                         organization, foreign private foundation, or government of 
To establish eligibility for exemption from 30% tax and       a U.S. territory receiving an amount subject to withholding 
withholding under sections 892, 895, 501(c), or 115(2), a     under sections 1441 through 1443 or a withholdable 

                                                              -2-         Instructions for Form W-8EXP (Rev. 10-2023)

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payment subject to chapter 4, or are such an entity             person will be the one from whom you receive the 
maintaining an account with an FFI requesting this form;        payment (including the transferee of a USRPI), who 
• A withholding qualified holder claiming an exemption to       credits your account, or a partnership that allocates 
withholding under section 1445;                                 income to you. Generally, a separate Form W-8EXP must 
• A foreign tax-exempt organization claiming an                 be given to each withholding agent.
exemption to withholding under section 1446(a) on your            Give Form W-8EXP to the person requesting it before 
allocable share of ECTI that is not includible under section    the payment is made, credited, or allocated to you or your 
512 and section 513 for purposes of computing unrelated         account. If you qualify for an exemption to tax, but do not 
business taxable income;                                        provide this form, the withholding agent may have to 
• A qualified holder claiming an exemption to withholding       withhold tax at the highest applicable rate. If you receive 
under section 1446(a) on its allocable share of ECTI that       more than one type of income from a single withholding 
is income subject to section 897; or                            agent, the withholding agent may require you to submit a 
• Otherwise establishing your status as a non-U.S.              Form W-8EXP for each different type of income.
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 
W-8EXP if you are:                                              form incorrect. In some cases, however, Form W-8EXP 
• Not a foreign government, international organization,         will remain valid only for a period starting on the date the 
foreign central bank of issue, foreign tax-exempt               form is signed and ending on the last day of the third 
organization, foreign private foundation, or government of      succeeding calendar year. For example, a Form W-8EXP 
a U.S. territory receiving amounts subject to withholding       provided on February 15, 2022, by a controlled entity of a 
under sections 1441 through 1443 claiming the                   foreign government would be subject to the 3-year validity 
applicability of section 115(2), 501(c), 892, 895, or           period and thus would expire on December 31, 2025, for 
1443(b). Instead, provide Form W-8BEN-E, or Form                sections 1441 through 1443 purposes. For more 
W-8ECI. For example, if you are a foreign tax-exempt            exceptions to the indefinite validity period, see:
organization claiming a benefit under an income tax treaty,     • Regulations section 1.1441-1(e)(4)(ii) for sections 1441 
provide Form W-8BEN-E.                                          through 1443 purposes,
• Receiving a withholdable payment from a withholding           • Regulation section 1.1445-5(b)(3)(ii)(B)(3) (2 years) for 
agent requesting this form and you do not have a                1445 purposes,
chapter 4 status identified in Part I, line 4 of this form.     • 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,         • Regulations section 1.1471-3(c)(6)(ii) for chapter 4 
nominee, or custodian). Instead, provide Form W-8IMY.           purposes.
• Receiving income that is effectively connected with the 
conduct of a trade or business in the United States.            Change in circumstances. If a change in circumstances 
Instead, provide Form W-8ECI, when applicable.                  makes any information on the Form W-8EXP you have 
• A tax-exempt organization receiving unrelated business        submitted incorrect, you must notify the withholding agent 
taxable income subject to withholding under section             within 30 days of the change in circumstances and you 
1443(a). Instead, provide Form W-8BEN-E or Form                 must file a new Form W-8EXP or other appropriate form. A 
W-8ECI (as applicable) for this portion of your income.         withholding qualified holder that fails to qualify as a 
• A foreign partnership, a foreign simple trust, a foreign      withholding qualified holder due to a change in 
complex trust, or a foreign grantor trust. Instead, provide     circumstances must notify the relevant entity before any 
Form W-8ECI, W-8BEN-E, or Form W-8IMY. However, a               further dispositions or distributions. See Regulations 
foreign grantor trust is required to provide documentation      section 1.1445-5(b)(3)(ii)(B)(3).
of its grantor or other owner for purposes of section 1446. 
                                                                Definitions
See Regulations section 1.1446-1. In addition, a foreign 
partnership may use this form to establish its status as a      Amounts exempt from tax under section 895.               Section 
withholding qualified holder exempt from withholding            895 generally excludes from gross income and exempts 
under section 1445.                                             from U.S. taxation income a foreign central bank of issue 
• A foreign partnership receiving a payment subject to          receives from obligations of the United States (or of any 
withholding under section 1445 and you don't qualify as a       agency or instrumentality thereof) or from interest on 
withholding qualified holder under section 1445 because         deposits with persons carrying on the banking business 
not all of your partners are qualified holders. In such a       unless such obligations or deposits are held for, or used in 
case, see Regulations section 1.1445-3 for procedures to        connection with, the conduct of commercial banking 
obtain a withholding certificate to reduce withholding.         functions or other commercial activities of the foreign 
• A foreign partnership claiming an exemption or                central bank of issue.
adjustment to withholding under section 1446(f) on an 
                                                                Amounts exempt from tax under section 892.               Only a 
amount realized on the transfer of an interest in a 
                                                                foreign government or an international organization as 
partnership.
                                                                defined below qualifies for exemption from taxation under 
Giving Form W-8EXP to the withholding agent.          Do        section 892. Section 892 generally excludes from gross 
not send Form W-8EXP to the IRS. Instead, give it to the        income and exempts from U.S. taxation income a foreign 
person who is requesting it from you. Generally, this           government receives from investments in the United 

Instructions for Form W-8EXP (Rev. 10-2023)                  -3-

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States in stocks, bonds, or other domestic securities;            Foreign partnerships, foreign simple trusts, and foreign 
financial instruments held in the execution of              grantor trusts are not the beneficial owners of income paid 
governmental financial or monetary policy; and interest on  to the partnership or trust. The beneficial owners of 
deposits in banks in the United States of monies            income paid to a foreign partnership are generally the 
belonging to the foreign government. Income of a foreign    partners in the partnership, provided that the partner is not 
government from any of the following sources is not         itself a partnership, foreign simple or grantor trust, 
exempt from U.S. taxation.                                  nominee, or other agent. The beneficial owners of income 
• The conduct of any commercial activity.                   paid to a foreign simple trust (that is, a foreign trust that is 
• A controlled commercial entity.                           described in section 651(a)) are generally the 
• The disposition of any interest in a controlled           beneficiaries of the trust, if the beneficiary is not a foreign 
commercial entity. For the definition of “commercial        partnership, foreign simple or grantor trust, nominee, or 
activity,” see Temporary Regulations section 1.892-4T.      other agent. The beneficial owners of income paid to a 
  Section 892 also generally excludes from gross income     foreign grantor trust (that is, a foreign trust to the extent 
and exempts from U.S. taxation income of an international   that all or a portion of the income of the trust is treated as 
organization received from investments in the United        owned by the grantor or another person under sections 
States in stocks, bonds, or other domestic securities and   671 through 679) are the persons treated as the owners of 
interest on deposits in banks in the United States of       the trust. The beneficial owners of income paid to a 
monies belonging to the international organization or from  foreign complex trust (that is, a foreign trust that is not a 
any other source within the United States.                  foreign simple trust or foreign grantor trust) is the trust 
                                                            itself.
Amounts subject to withholding.   Generally, an amount 
                                                                  The beneficial owner of income paid to a foreign estate 
subject to withholding under sections 1441 through 1443 
                                                            is the estate itself.
is an amount from sources within the United States that is 
fixed or determinable annual or periodical (FDAP) income.         These beneficial owner rules apply primarily for 
FDAP income is all income included in gross income,         purposes of withholding under sections 1441 and 1442. 
including interest (as well as OID), dividends, rents,      The rules also generally apply for purposes of section 
royalties, and compensation. FDAP income does not           1446, with a few exceptions. See Regulations section 
include most gains from the sale of property (including     1.1446-1 for instances where the documentation 
market discount and option premiums), as well as other      requirements of sections 1441 and 1442 differ from 
specific items of income described in Regulations section   section 1446.
1.1441-2 (such as interest on bank deposits and                   For purposes of completing Form W-8EXP, a foreign 
short-term OID).                                            partnership that is a withholding qualified holder under 
  For purposes of sections 1445 and 1446(f), the amount     section 1445 should be identified as the beneficial owner.
subject to withholding is generally the transferor's amount Chapter 3. Chapter 3 means chapter 3 of the Internal 
realized.                                                   Revenue Code (Withholding of Tax on Nonresident Aliens 
  For purposes of section 1446(a), the amount subject to    and Foreign Corporations) under sections 1441 through 
withholding is the foreign partner’s allocable share of the 1464.
partnership’s ECTI.
                                                            Chapter 4. Chapter 4 means chapter 4 of the Internal 
  An amount subject to chapter 4 withholding is an          Revenue Code (Taxes to Enforce Reporting on Certain 
amount of U.S. source FDAP income that is also a            Foreign Accounts). Chapter 4 contains sections 1471 
withholdable payment as defined in Regulations section      through 1474.
1.1473-1(a) to which an exception does not apply under 
chapter 4. The exemptions from withholding or taxation      Commercial activities. For purposes of chapter 4, 
provided for under chapter 3 are not applicable when        commercial activities are financial activities of a type 
determining whether withholding applies under chapter 4.    engaged in by an insurance company, custodial institution, 
For exceptions applicable to the definition of a            or depository institution (including the act of accepting 
withholdable payment, see Regulations section               deposits). An exempt beneficial owner will not be 
1.1473-1(a)(4) (exempting, for example, certain             considered exempt for chapter 4 purposes with respect to 
nonfinancial payments).                                     payments derived from an obligation held in connection 
                                                            with a commercial financial activity. See Regulations 
Beneficial owner.  For payments other than those for        section 1.1471-6(h), including limitations on the scope of 
which a reduced rate of, or exemption from, withholding is  a commercial financial activity. For purposes of chapter 3, 
claimed under an income tax treaty, the beneficial owner    commercial activities are described in Temporary 
of income is generally the person who is required under     Regulations section 1.892-4T.
U.S. tax principles to include the payment in gross income 
on a tax return. A person is not a beneficial owner of      Controlled commercial entity. A controlled commercial 
income, however, to the extent that person is receiving the entity is an entity engaged in commercial activities 
income as a nominee, agent, or custodian, or to the extent  described in Temporary Regulations section 1.892-4T 
the person is a conduit whose participation in a            (whether conducted within or outside the United States) if 
transaction is disregarded. In the case of amounts paid     the foreign government holds (directly or indirectly):
that do not constitute income, beneficial ownership is          • Any interest in the entity which (by value or voting 
determined as if the payment were income.                   power) is 50% or more of the total of such interests in the 
                                                            entity, or

                                                            -4-          Instructions for Form W-8EXP (Rev. 10-2023)

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• A sufficient interest (by value or voting power) or any       of International Settlements is treated as though it were a 
other interest in the entity which provides the foreign         foreign central bank of issue.
government with effective practical control of the entity.        A foreign central bank of issue must provide Form 
  For this purpose, an entity means a corporation, a            W-8EXP to establish eligibility for exemption from 
partnership, a trust (including a pension trust), and an        withholding for payments exempt from tax under either 
estate. A partnership’s commercial activities are               section 892 or section 895.
attributable to its general and, subject to Proposed 
                                                                Foreign financial institution (FFI). An FFI generally 
Regulations section 1.892-5(a)(5), limited partners for 
                                                                means a foreign entity that is a financial institution.
purposes of determining whether the partner is a 
controlled commercial entity for purposes of section 892.       Foreign person.     A foreign person includes a nonresident 
The partnership’s commercial activities will result in the      alien individual, foreign corporation, foreign partnership, 
partnership having to withhold tax under section 1446 on        foreign trust, foreign estate, foreign government, 
commercial income that is the ECTI allocable to a foreign       international organization, foreign central bank of issue, 
government partner.                                             foreign tax-exempt organization, foreign private 
                                                                foundation, or government of a U.S. territory, and any 
Note. A foreign central bank of issue will be treated as a      other person that is not a U.S. person. It also includes a 
controlled commercial entity only if it engages in              foreign branch or office of a U.S. financial institution or 
commercial activities within the United States.                 U.S. clearing organization if the foreign branch is a 
Chapter 4 status. The term chapter 4 status means a             qualified intermediary. Generally, a payment to a U.S. 
person’s status as a U.S. person, specified U.S. person,        branch of a foreign person is a payment to a foreign 
foreign person participating FFI deemed-compliant FFI, ,   ,    person.
restricted distributor, exempt beneficial owner,                Foreign government.  For chapter 3 purposes, a foreign 
nonparticipating FFI, territory financial institution,          government includes only the integral parts or controlled 
excepted nonfinancial foreign entity (NFFE), or passive         entities of a foreign sovereign as defined in Temporary 
NFFE. See Regulations section 1.1471-1(b) for the               Regulations section 1.892-2T. See Regulations section 
definitions of these terms.                                     1.1471-6(b) for definitions of integral part and controlled 
Deemed-compliant FFI.       Under section 1471(b)(2),           entity that apply for chapter 4 purposes.
certain FFIs are deemed to comply with the regulations            An integral part of a foreign sovereign, in general, is any 
under chapter 4 without the need to enter into an FFI           person, body of persons, organization, agency, bureau, 
agreement with the IRS. However, certain                        fund, instrumentality, or other body, however designated, 
deemed-compliant FFIs are required to register with the         that constitutes a governing authority of a foreign country. 
IRS and obtain a Global Intermediary Identification             The net earnings of the governing authority must be 
Number (GIIN). These FFIs are referred to as registered         credited to its own account or to other accounts of the 
deemed-compliant FFIs. See Regulations section                  foreign sovereign, with no portion benefiting any private 
1.1471-5(f).                                                    person.
Exempt beneficial owner.    An exempt beneficial owner            A controlled entity of a foreign sovereign is an entity 
means a person that is described in Regulations section         that is separate in form from the foreign sovereign or 
1.1471-6 and includes a foreign government, a political         otherwise constitutes a separate juridical entity only if:
subdivision of a foreign government, a wholly owned             • It is wholly owned and controlled by the foreign 
instrumentality or agency of a foreign government or            sovereign directly or indirectly through one or more 
governments, an international organization, a wholly            controlled entities.
owned agency or instrumentality of an international             • It is organized under the laws of the foreign sovereign 
organization, a foreign central bank of issue, a                by which it is owned.
government of a U.S. territory, certain retirement funds,       • Its net earnings are credited to its own account or to 
and certain entities wholly owned by one or more exempt         other accounts of the foreign sovereign, with no portion of 
beneficial owners. In addition, an exempt beneficial owner      its income inuring to the benefit of any private person.
includes any person treated as an exempt beneficial             • Its assets vest in the foreign sovereign upon dissolution.
owner under an applicable Model 1 IGA or Model 2 IGA              A controlled entity of a foreign sovereign also includes 
(defined later).                                                a pension trust defined in Temporary Regulations section 
                                                                1.892-2T(c) and may include a foreign central bank of 
Financial institution.  A financial institution generally 
                                                                issue to the extent that it is wholly owned by a foreign 
means an entity that is a depository institution, custodial 
                                                                sovereign.
institution, investment entity, or an insurance company (or 
holding company of an insurance company) that issues              A foreign government must provide Form W-8EXP to 
cash value insurance or annuity contracts. See                  establish eligibility for exemption from withholding for 
Regulations section 1.1471-5(e).                                payments exempt from tax under section 892 or for 
                                                                purposes of establishing its status as an exempt beneficial 
Foreign central bank of issue.    A foreign central bank of     owner.
issue is a bank that is by law or government sanction the 
principal authority, other than the government itself, to       Intergovernmental agreement (IGA).       An IGA means a 
issue instruments intended to circulate as currency. Such       Model 1 IGA or a Model 2 IGA. For a list of jurisdictions 
a bank is generally the custodian of the banking reserves       treated as having in effect a Model 1 or Model 2 IGA, see 
of the country under whose law it is organized. The Bank 

Instructions for Form W-8EXP (Rev. 10-2023)                  -5-

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the list of jurisdictions at home.treasury.gov/Policy-Issues/  pension fund) or a qualified controlled entity that satisfies 
Tax-Policy/Foreign-Account-Tax-Compliance-Act.                 the requirements of either Regulations section 
A Model 1 IGA means an agreement between the                   1.897(l)-1(d)(2) or Regulations section 1.897(l)-1(d)(3).
United States or the Treasury Department and a foreign         Qualified investment entity. A qualified investment 
government or one or more agencies to implement FATCA          entity is a person described in section 897(h)(4).
through reporting by FFIs to such foreign government or 
agency thereof, followed by automatic exchange of the          Specified U.S. person. A specified U.S. person is any 
reported information with the IRS. An FFI in a Model 1 IGA     U.S. person other than a person identified in Regulations 
jurisdiction that performs account reporting to the            section 1.1473-1(c).
jurisdiction’s government is referred to as a reporting        Substantial U.S. owner.   A substantial U.S. owner (as 
Model 1 FFI.                                                   described in Regulations section 1.1473-1(b)) means any 
A Model 2 IGA means an agreement or arrangement                specified U.S. person that:
between the United States or the Treasury Department               • Owns, directly or indirectly, more than 10% (by vote or 
and a foreign government or one or more agencies to            value) of the stock of any foreign corporation;
implement FATCA through reporting by FFIs directly to the          • Owns, directly or indirectly, more than 10% of the profits 
IRS in accordance with the requirements of an FFI              interests or capital interests in a foreign partnership;
agreement, supplemented by the exchange of information             • Is treated as an owner of any portion of a foreign trust 
between such foreign government or agency thereof and          under sections 671 through 679; or
the IRS. An FFI in a Model 2 IGA jurisdiction that has             • Holds, directly or indirectly, more than a 10% beneficial 
entered into an FFI agreement with respect to a branch is      interest in a trust.
a participating FFI, but may be referred to as a reporting     Territory financial institution.  The term territory 
Model 2 FFI.                                                   financial institution means a financial institution that is 
International organization.  For purposes of chapter 3,        incorporated or organized under the laws of any U.S. 
an international organization is any public international      territory. However, an investment entity that is not also a 
organization entitled to enjoy privileges, exemptions, and     depository institution, custodial institution, or specified 
immunities as an international organization under the          insurance company is not a territory financial institution.
International Organizations Immunities Act (22 U.S.C.          Withholdable payment.     The term withholdable payment 
288-288(f)). In general, to qualify as an international        means an amount subject to withholding for purposes of 
organization, the United States must participate in the        chapter 4 as described in Amounts subject to withholding, 
organization pursuant to a treaty or under the authority of    earlier. Also see Regulations section 1.1473-1(a) for the 
an Act of Congress authorizing such participation.             definition of withholdable payment.
Any organization that qualifies as an international            Withholding agent.  Any person, U.S. or foreign, that has 
organization under chapter 3 also qualifies as an              control, receipt, custody, disposal, or payment of U.S. 
international organization under chapter 4.                    source FDAP income subject to chapter 3 or 4 withholding 
For purposes of chapter 4, an international organization       is a withholding agent. The withholding agent may be an 
also includes any intergovernmental or supranational           individual, corporation, partnership, trust, association, or 
organization that is comprised primarily of foreign            any other entity, including (but not limited to) any foreign 
governments, that is recognized as an intergovernmental        intermediary, foreign partnership, and U.S. branches of 
or supranational organization under a foreign law similar to   certain foreign banks and insurance companies.
22 U.S.C. 288-288(f) or that has in effect a headquarters 
agreement with a foreign government, and whose income          Withholding qualified holder.     The term withholding 
does not inure to the benefit of private persons.              qualified holder means a qualified holder (under 
                                                               Regulations section 1.897(l)-1(d)), and a foreign 
Participating FFI.   A participating FFI is an FFI that has    partnership all of the interests of which are held by 
agreed to comply with the terms of an FFI agreement with       qualified holders (under Regulations section 
respect to all branches of the FFI, other than a branch that   1.897(l)-1(d)), including through one or more partnerships.
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       Specific Instructions
branch is a reporting Model 1 FFI.
                                                               Part I — Identification of Beneficial 
Qualified controlled entity. A qualified controlled entity 
is a trust or corporation created or organized under the       Owner
laws of a foreign jurisdiction, all of the interests of which  Before completing Part I, complete the Worksheet for 
are held by one or more qualified foreign pension funds        Foreign Governments, International Organizations, and 
directly or indirectly through one or more qualified           Foreign Central Banks of Issue, later, to determine 
controlled entities.                                           whether amounts received are or will be exempt from U.S. 
                                                               tax under section 892 or 895 and exempt from withholding 
Qualified foreign pension fund.   A qualified foreign 
                                                               under sections 1441 and 1442. Use the results of this 
pension fund is a person that satisfies the requirements of 
                                                               worksheet to check the appropriate box on line 3 and in 
section 897(l) and Regulations section 1.897(l)-1.
                                                               Part II. Do not give the worksheet to the withholding agent. 
Qualified holder.    A qualified holder is a qualified foreign Instead, keep it for your records.
pension fund (including a part of a qualified foreign 
                                                               Line 1. Enter the full name of the organization.

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Line 2. Enter the country under the laws of which the            Line 5. The permanent address of a foreign government, 
foreign government or other foreign organization was             international organization, or foreign central bank of issue 
created, incorporated, organized, or governed.                   is where it maintains its principal office. For all other 
                                                                 organizations, the permanent address is the address in 
Line 3. Check the one box that applies (unless you are 
                                                                 the country where the organization claims to be a resident 
also documenting yourself as a withholding qualified 
                                                                 for tax purposes. Do not show the address of a financial 
holder under section 1445). A foreign central bank of 
                                                                 institution, a post office box, or an address used solely for 
issue (wholly owned by a foreign sovereign) should check 
                                                                 mailing purposes unless such address is the only 
the “Foreign government” box. If you are a foreign private 
                                                                 permanent address you use and it appears as your 
foundation, you should check the “Foreign private 
                                                                 registered address in your organizational documents.
foundation” box rather than the “Foreign tax-exempt 
organization” box. If you are providing this form to claim an    Line 6. Enter the mailing address only if it is different from 
exemption to withholding under section 1445 as a                 the address shown on line 5.
qualified foreign pension fund that is a qualified holder 
                                                                 Line 7. A U.S. taxpayer identification number (TIN) 
(within the meaning of Regulations section 1.897(l)-1(e)
                                                                 means an employer identification number (EIN). A U.S. 
(11)) or as a foreign partnership, all of the interests of       TIN is generally required if you are claiming an exemption 
which are held by qualified holders, including through one       or reduced rate of withholding based solely on your claim 
or more partnerships, you should check the “Withholding          of tax-exempt status under section 501(c) or private 
qualified holder under section 1445” box. See Regulations 
                                                                 foundation status. Use Form SS-4 to obtain an EIN.
section 1.1445-1(g)(11). For purposes of completing this 
Form W-8EXP, a foreign partnership that is a withholding         Line 8a. If the organization has registered with the IRS as 
qualified holder should identify itself as the beneficial        a participating FFI (including a reporting Model 2 FFI), 
owner.                                                           registered deemed-compliant FFI (including a reporting 
If you are providing this form to document yourself as a         Model 1 FFI), or a direct reporting NFFE, provide your 
withholding qualified holder under section 1445 and for          GIIN. For payments made prior to January 1, 2015, a 
purposes of sections 1441-1443 or section 1446, check            Form W-8EXP provided by a reporting Model 1 FFI need 
the "Withholding qualified holder under section 1445" box        not contain a GIIN. For payments made prior to January 1, 
and the one box that otherwise applies to your status. In        2016, a sponsored direct reporting NFFE may provide the 
all other cases, only one box should be checked.                 GIIN of its sponsoring entity.
Line 4. Check the one box that applies to your chapter 4         Line 8b. If you are providing this Form W-8EXP to 
status (if necessary). You are required to provide a             document yourself as an account holder (as defined in 
chapter 4 status if you are the payee of a withholdable          Regulations section 1.1471-5(a)(3)) with respect to a 
payment or hold an account with an FFI requesting this           financial account (as defined in Regulations section 
form. See Regulations section 1.1471-3(a) for the                1.1471-5(b)) that you hold at a U.S. office of a financial 
definition of a payee for purposes of chapter 4. By              institution (including a U.S. branch of an FFI) and you 
checking a box on this line, you are representing that you       receive U.S. source income reportable on a Form 1042-S 
qualify for this classification and, if you are claiming a       associated with this form, you must provide on line 8b the 
status as an exempt beneficial owner, that you are the           foreign TIN (FTIN) issued to you by the jurisdiction in 
beneficial owner of the payments to which this form              which you are a tax resident identified on line 5 unless:
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      Businesses/Corporations/List-of-Jurisdictions-That-Do-
TIP     complete an additional line on this form certifying      Not-Issue-Foreign-TINs; or
        that you meet the conditions of the status               • You properly identified yourself as a foreign 
indicated on line 4 (as defined under Regulations section        government, foreign central bank of issue, international 
1.1471-5 or 1.1471-6 or an applicable IGA). Make sure            organization, or government of a U.S. territory on line 3.
you complete the required portion of this form before 
                                                                   If you are providing this form to document a financial 
signing and providing it to the withholding agent.
                                                                 account described above but you do not enter an FTIN on 
                                                                 line 8b, and you are not a foreign government, foreign 
        If you do not certify as to your chapter 4 status, 
                                                                 central bank of issue, international organization, or 
!       this Form W-8EXP will not be valid for purposes of       government of a U.S. territory, you must provide the 
CAUTION chapter 4 if you receive a withholdable payment at 
                                                                 withholding agent with an explanation of why you have not 
any time in the future. For example, if you do not certify as 
                                                                 been issued a TIN (including if the jurisdiction does not 
to your chapter 4 status because the only payments you 
                                                                 issue TINs). For this purpose, an explanation is a 
receive from the withholding agent are with respect to 
                                                                 statement that you are not legally required to obtain a TIN 
grandfathered obligations described in Regulations 
section 1.1471-2(b), then you will be required to resubmit       in your jurisdiction of tax residence. The explanation may 
                                                                 be written on line 8b, in the margins of the form, or on a 
Form W-8EXP and certify to your chapter 4 status if you 
                                                                 separate attached statement associated with the form. If 
receive a withholdable payment in the future. You may 
                                                                 you are writing the explanation on line 8b, you may 
consider certifying to your chapter 4 status even if not 
                                                                 shorten it to “not legally required.” Do not write “not 
required in order to avoid resubmitting Form W-8EXP to 
                                                                 applicable.”
the withholding agent. See Expiration of Form W-8EXP, 
earlier.

Instructions for Form W-8EXP (Rev. 10-2023)                   -7-

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If you are providing this form to certify your status as a    officers. The affidavit must include information on your 
withholding qualified holder under section 1445 and did       financial support if you are claiming public charity status 
not provide an EIN on line 7, provide your FTIN on line 8b.   under sections 509(a)(1) and 170(b)(1)(A)(vi) or section 
                                                              509(a)(2). See Publication 557, Tax-Exempt Status for 
Line 9. This line may be used by the filer of Form 
                                                              Your Organization, for information on determining whether 
W-8EXP or by the withholding agent to whom it is 
                                                              you are a public charity or private foundation.
provided to include any referencing information that is 
necessary or useful to the withholding agent in carrying            In lieu of providing information in an affidavit concerning 
out its obligations. For example, a filer may use line 9 to   your operations, support, and financial information (when 
include the name and number of the account for which the      applicable), you may satisfy this requirement by 
filer is providing the form.                                  referencing the opinion of U.S. counsel provided in 
                                                              accordance with Box 13b of these instructions when the 
Part II — Qualification Statement for                         opinion:
Chapter 3 Status                                                  • Concludes that you qualify under section 509(a)(1), (2), 
                                                              (3), or (4); and
        You are not required to complete a chapter 3              • Meets the requirements of current written advice 
TIP     qualification statement if you are submitting this    rendered for a public charity equivalency determination in 
        form to document your chapter 4 status and are        Rev. Proc. 2017-53, 2017-40 I.R.B. 263.
not receiving a payment that is subject to withholding                If the opinion of U.S. counsel satisfies the above 
under chapter 3. However, in such a case, you may also            TIP requirements, you may check this box despite that 
provide Form W-8BEN-E to document your chapter 4                      it references only the affidavit on this form.
status.
                                                                    An opinion of counsel or affidavit must be renewed if 
Line 10. All foreign governments claiming the                 there has been a change in facts relevant to your 
applicability of section 892 must check box 10a as well as    tax-exempt status under section 501(c) or your public 
box 10b or box 10c, whichever applies. Enter the name of      charity status under section 509.
the foreign sovereign’s country on line 10b (if the entity is       Box 13d. Check this box if you are a section 501(c)(3) 
an integral part of a foreign government) or on line 10c (if  organization and you are a private foundation described in 
the entity is a controlled entity of a foreign government). A section 509.
foreign central bank of issue (wholly owned by a foreign 
sovereign) should check box 10c.                              Line 14.  Check this box if you are a government of a U.S. 
                                                              territory. By checking this box you are certifying to the 
Line 11. Check this box if you are an international           statements made in line 14.
organization. By checking this box, you are certifying to all 
the statements made in line 11.                               Line 15.  Check the applicable box if you are a 
                                                              withholding qualified holder. By checking one of these 
Line 12. Check this box if you are a foreign central bank     boxes, you are certifying to the statement made in either 
of issue for purposes of chapter 3 (see definitions) not      line 15a or line 15b, as applicable.
wholly owned by a foreign sovereign. By checking this 
box, you are certifying to all the statements made in         Part III — Qualification Statement for 
line 12.
                                                              Chapter 4 Status
Line 13. If you are a foreign tax-exempt organization, you 
must attach a statement setting forth any income that is              You are not required to complete a chapter 4 
includible under section 512 in computing your unrelated          TIP qualification statement if you are not the payee of 
business taxable income.                                              a withholdable payment or are not an 
Box 13a.    Check this box if you have been issued a          accountholder holding an account with an FFI requesting 
determination letter by the IRS. Enter the date of the IRS    this form.
determination letter.
                                                              Line 16.  Check this box to indicate that you are treated 
Box 13b.    Check this box if you do not have an IRS          as a nonreporting FFI under an applicable IGA (and as 
determination letter, but are providing an opinion of U.S. 
                                                              defined in the IGA). You must identify the applicable IGA 
counsel concluding that you are an organization described     by entering the name of the jurisdiction that has the 
in section 501(c).
                                                              applicable IGA in effect with the United States. You must 
Box 13c.    If you are a section 501(c)(3) organization,      also provide the withholding agent with the class of entity 
check this box if you are not a private foundation. You       described in Annex II of the IGA applicable to your status. 
must attach to the withholding certificate an affidavit       If you are an FFI treated as a registered 
setting forth sufficient facts concerning your operations     deemed-compliant FFI under an applicable Model 2 IGA, 
and support to enable the IRS to determine that you would     you must provide your GIIN in the space provided.
be likely to qualify as an organization described in section 
509(a)(1), (2), (3), or (4) rather than as a private          Line 17.  Check this box if you are a territory financial 
foundation.                                                   institution. By checking this box, you are certifying to the 
                                                              statement in line 17.
The affidavit must be based on information from your 
latest accounting year, identify the type of section 501(c)   Line 18.  Check this box if you are a foreign government, 
(3) organization (for example, charitable, religious,         government of a U.S. territory, or foreign central bank of 
educational), and be signed by one of your principal          issue as defined for purposes of chapter 4 (see 

                                                              -8-             Instructions for Form W-8EXP (Rev. 10-2023)

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Regulations section 1.1471-6). By checking this box, you        indicate that the form was electronically signed by a 
are certifying to the statement made in line 18.                person authorized to do so (for example, with a time and 
                                                                date stamp and statement that the form has been 
Line 19. Check the applicable box if you are an exempt 
                                                                electronically signed). Simply typing your name into the 
retirement plan of a foreign government as defined for 
                                                                signature line is not an electronic signature.
purposes of chapter 4. By checking one of these boxes, 
you are certifying to the statement made in either line 19a 
                                                                Paperwork Reduction Act Notice. We ask for the 
or line 19b, as applicable.
                                                                information on this form to carry out the Internal Revenue 
Line 20. Check this box if you are a 501(c) organization        laws of the United States. You are required to provide the 
other than an insurance company described in section            information. We need it to ensure that you are complying 
501(c)(15). By checking this box, you are certifying to the     with these laws and to allow us to figure and collect the 
statement made in line 20.                                      right amount of tax.
Line 21. Check box 21a if you are passive NFFE. If you          You are not required to provide the information 
do not have any substantial U.S. owners, check box 21b. If      requested on a form that is subject to the Paperwork 
you have any substantial U.S. owners, you must provide a        Reduction Act unless the form displays a valid OMB 
statement with the information set forth on line 21c.           control number. Books or records relating to a form or its 
Line 22. Check this box if you are a sponsored direct           instructions must be retained as long as their contents 
reporting NFFE. Provide the name of your sponsoring             may become material in the administration of any Internal 
entity in the space provided. By checking this box, you are     Revenue law. Generally, tax returns and return information 
certifying to the statement made in line 22.                    are confidential, as required by section 6103.
                                                                The time needed to complete and file this form will vary 
Part IV — Certification                                         depending on individual circumstances. The estimated 
Form W-8EXP must be signed and dated by an authorized           average time is: Recordkeeping, 7hr., 10min.; Learning 
official of the foreign government, international               about the law or the form, 5 hr., 42 min.; and Preparing 
organization, foreign central bank of issue, foreign            and providing the form, 8 hr., 27 min.
tax-exempt organization, foreign private foundation, 
government of a U.S. territory, or withholding qualified        If you have comments concerning the accuracy of 
holder, as appropriate. By signing Form W-8EXP, the             these time estimates or suggestions for making this form 
authorized representative, officer, or agent also agrees to     simpler, we would be happy to hear from you. You can 
provide a new form within 30 days following a change in         send us comments from IRS.gov/FormComments. You 
circumstances that makes any certification made on the          can write to the Internal Revenue Service, Tax Forms and 
form incorrect (unless no future payments will be made to       Publications, 1111 Constitution Ave. NW, IR-6526, 
the organization by the withholding agent). The authorized      Washington, DC 20224. Do not send Form W-8EXP to 
representative, officer, or agent must also check the box to    this office. Instead, give it to your withholding agent.
certify that he or she has the capacity to sign for the 
organization.
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)                  -9-

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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  . If “No,” answer question 4 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   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
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 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                                                                                                                                                     Yes No
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 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.)
  c 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.)

                                                              -10-