PART C: FATCA-CRS

INSTRUCTIONS & DEFINITIONS

1. Financial Institution (FI) - The term FI means any financial institution that is a Depository Institution, Custodial Institution, Investment Entity or Specified Insurance company, as defined.

(i) Depository institution: is an entity that accepts deposits in the ordinary course of banking or similar business.

(ii) Custodial institution isan entity that holds as a substantial portion of its business, holds financial assets for the account of others and where it’s income attributale to holding financial
assets and related financial services equals or exceeds 20 percent of the entity's gross income during the shorter of
a) The three financial years preceding the year in which determination is made; or
b) The period during which the entity has been in existence, whichever is less.

(iii) Investment entity is any entity:

a) That primarily conducts a business or operates for or on behalf of a customer for any of the following activities or operations for or on behalf of acustomer
(i) Trading in money market instruments (cheques, bills, certificates of deposit, derivatives, etc.); foreign exchange; exchange, interest rate and index instrumens;
transferable securities; or commodity futures trading; or
(ii) Individual and collective portfolio management; or
(iii) Investing, administering or managing funds,money or financial asset or money on behalf of other persons ;

or

b) The grossincome of which is primarily attributable to investing, reinvesting, or trading in financial assets, if the entity is managed by another entity that is a depository
institution, a custodial institution, a specified insurance company, or an investment entity described above.

An entity is treated as primarily conducting as a business one or more of the 3 activities described above, or an entity’s gross income is primarily attributable to investing,
reinvesting, or trading in financial assets of the entity’s gross income attributable to the relevant activities equals or exceeds 50 percent of the entity’s gross income during
the shorter of:
(i) the three-year period ending on 31 March of the year preceding the year in which the determination is made; or
(ii) the period during which the entity has been in existence.

The term “Investment Entity” does not include an entity that is an active non-financial entity as per codes 03, 04, 05 and 06 - refer point 2c. ) In case the entity confirms it is
an FI and a tax resident outside India, an additional CRS declaration will need to be filled. Refer Annexure A

(iv) Specified Insurance Company: Entity that is an insurance company (or the holding company of an insurance company) that issues, or is obligated to make payments with respect to, a
Cash Value Insurance Contract or an Annuity Contract.

1A. FIs not required to apply for GIIN:

Code Sub-category

01 Governmental Entity, International Organization or Central Bank

02 Treaty Qualified Retirement Fund; a Broad Participation Retirement Fund; a Narrow Participation Retirement Fund; or a Pension Fund of a Governmental Entity, International
Organization or Central Bank

03 Non-public fund of the armed forces, an employees’ state insurance fund, a gratuity fund or a provident fund

04 Entity is an Indian FI solely because it is an investment entity

05 Qualified credit card issuer

06 Investment Advisors, Investment Managers & Executing Brokers

07 Exempt collective investment vehicle

08 Indian trust where the trustee is a reporting FI

09 FI with a local client base

10 Non-registering local banks

11 FFI with only Low-Value Accounts

12 Sponsored investment entity and controlled foreign corporation

13 Sponsored, Closely Held Investment Vehicle

14 Owner Documented FFI (if you select this category, please provideOwner Reporting Statement or an Auditor’s Letter with required details as mentioned in Form W8 BEN E)

2. Non-financial entity (NFE) – Any entity that is not a financial institution

Types of NFEs that are regarded as excluded NFE are:
a. Publicly traded company (listed company)
A company is publicly traded if its stock are regularly traded on one or more established securities markets (Established securities market means an exchange that is officially recognized and
supervised by a governmental authority in which the securities market is located and that has a meaningful annual value of shares traded on the exchange)
b. Related entity of a publicly traded company
The NFE is a related entity of an entity of which is regularly traded on an established securities market;
c. Active NFE : (is any one of the following):

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 Code Sub-category
01 Less than 50 percent of the NFE’s gross income for the preceding financial year is passive income and less than 50 percent of the assets held by the NFE during the preceding
financial year are assets that produce or are held for the production of passive income;
02 The NFE is a Governmental Entity, an International Organization, a Central Bank , or an entity wholly owned by one or more of the foregoing;
03 Substantially all of the activities of the NFE consist of holding (in whole or in part) the outstanding stock of, or providing financing and services to, one or more subsidiaries that engage
in trades or businesses other than the business of a Financial Institution, except that an entity shall not qualify for this status if the entity functions as an investment fund, such as a
private equity fund, venture capital fund, leveraged buyout fund, or any investment vehicle whose purpose is to acquire or fund companies and then hold interests in those companies
as capital assets for investment purposes;
04 The NFE is not yet operating a business and has no prior operating history, but is investing capital into assets with the intent to operate a business other than that of a Financial
Institution, provided that the NFE shall not qualify for this exception after the date that is 24 months after the date of the initial organization of the NFE;
05 The NFE was not a Financial Institution in the past five years, and is in the process of liquidating its assets or is reorganizing with the intent to continue or recommence operations
in a business other than that of a Financial Institution;
06 The NFE primarily engages in financing and hedging transactions with, or for, Related Entities that are not Financial Institutions, and does not provide financing or hedging services
to any Entity that is not a Related Entity, provided that the group of any such Related Entities is primarily engaged in a business other than that of a Financial Institution;
07 Any NFE that fulfills all of the following requirements:
• It is established and operated in India exclusively for religious, charitable, scientific, artistic, cultural, athletic, or educational purposes; or it is established and operated in India and
it is a professional organization, business league, chamber of commerce, labor organization, agricultural or horticultural organization, civic league or an organization operated
exclusively for the promotion of social welfare;
• It is exempt from income tax in India;
• It has no shareholders or members who have a proprietary or beneficial interest in its income or assets;
• The applicable laws of the NFE’s country or territory of residence or the NFE’s formation documents do not permit any income or assets of the NFE to be distributed to, or applied
for the benefit of, a private person or non-charitable Entity other than pursuant to the conduct of the NFE’s charitable activities, or as payment of reasonable compensation for
services rendered, or as payment representing the fair market value of property which the NFE has purchased; and

The applicable laws of the NFE’s country or territory of residence or the NFE’s formation documents require that, upon the NFE’s liquidation or dissolution, all of its assets be distribut-
ed to a governmental entity or other non-profit organization, or escheat to the government of the NFE’s country or territory of residence or any political subdivision thereof.

Explanation.- For the purpose of this sub-clause, the following shall be treated as fulfilling the criteria provided in the said sub-clause, namely:-
(I) an Investor Protection Fund referred to in clause (23EA);
(II) a Credit Guarantee Fund Trust for Small Industries referred to in clause 23EB; and
(III) an Investor Protection Fund referred to in clause (23EC),
of section 10 of the Act;

3. Other definitions
(i) Related entity
An entity is a ‘related entity’ of another entity if either entity controls the other entity, or the two entities are under common control For this purpose, control includes direct or indirect ownership
of more than 50% of the votes and value in an entity.
(ii) Passive NFE
The term passive NFE means
(a) any non-financial entity which is not an active non-financial entity including a publicly traded corporation or related entity of a publicly traded company; or
(b) an investment entity defined in clause 1(iii)(b) of these instructions which is not located in any of the jurisdictions specified by the Central Board of Direct Taxes in this behalf.
(c) not a withholding foreign partnership or withholding foreign trust; (Note: Foreign persons having controlling interest in a passive NFE are liable to be reported for tax information compliance
purposes)
(iii) Passive income
The term passive income includes income by way of :
(1) Dividends,
(2) Interest
(3) Income equivalent to interest,
(4) Rents and royalties, other than rents and royalties derived in the active conduct of a business conducted, at least in part, by employees of the NFE
(5) Annuities
(6) The excess of gains over losses from the sale or exchange of financial assets that gives rise to passive income
(7) The excess of gains over losses from transactions (including futures, forwards, options and similar transactions) in any financial assets,
(8) The excess of foreign currency gains over foreign currency losses
(9) Net income from swaps
(10) Amounts received under cash value insurance contracts
But passive income will not include, in case of a non-financial entity that regularly acts as a dealer in financial assets, any income from any transaction entered into in the ordinary course of
such dealer’s business as such a dealer.
(iv) Controlling persons
Controlling persons are natural persons who exercise control over an entityand includes a beneficial owner under sub-rule (3) ofrule 9 of the Prevention of Money-Laundering (Maintenance of
Records) Rules, 2005.In the case of a trust, the controlling person means the settlor, the trustees, the protector (if any), the beneficiaries or class of beneficiaries, and any other natural person
exercising ultimate effective control over the trust. In the case of a legal arrangement other than a trust, controlling person means persons in equivalent or similar positions.
Pursuant to guidelines on identification of Beneficial Ownership issued vide RBI circular no. DBOD.AML.BC. No.71/14.01.001/2012-13 dated January 18, 2013, persons(other than Individuals)
are required to provide details ofBeneficial Owner(s) (‘BO’). Accordingly, the Beneficial Owner means‘Natural Person’, who, whether acting alone or together, or through one or more juridical
person, exercises control through ownership or who ultimately has a controlling ownership interest of / entitlements to:
a. More than 10% ofshares or capital or profits of the juridical person, where the juridical person is a company;
b. More than 15% of the capital or profits of the juridical person, where the juridical person is a partnership; or
c. More than 15% of the property or capital or profits of the juridical person, where the juridical person is an unincorporated association or body of individuals.
d. Where the client is a trust, the financial institution shall identify the beneficial owners of the client and take reasonable measures to verify the identity ofsuch persons, through the identity of
the Author/Settlor/Grantor of the trust and the trustee, and the beneficiaries with 10% or more interest in the trust and any other natural person exercising ultimate effective control over the
trust through a chain of control or ownership.

Note -Where no natural person isidentified is the relevant natural person who holds the position of senior managing official

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 Type of Legal Entity Controlling Person Type Controlling Person Permissible Value / Details
Type Code
Owners / (Partners) C01 C01 CP of legal person-ownership
Partnership Firms / LLP
Senior Managing Officials C03 C03 CP of legal person-senior managing official
Owners / (Partners) C01 C01 CP of legal person-ownership
Pvt. Ltd. / Public Ltd. Companies
Senior Managing Officials C03 C03 CP of legal person-senior managing official
Members / Committee Members C01 C01 CP of legal person-ownership
Society
Senior Managing Officials C03 C03 CP of legal person-senior managing official
Owners / (Members) C01 C01 CP of legal person-ownership
Association of Person
Others C03 C03 CP of legal person-senior managing official
Trustee C05 C05 CP of legal arrangement - trust - trustee
Trust
Beneficiaries C07 C07 CP of legal arrangement - trust - beneficiary
Settler C04 C04 CP of legal arrangement - trust - settlor
Others C08 C08 CP of legal arrangement - trust - other
Owners / Directors C01 C01 CP of legal person-ownership
Company US 8/25
Senior Managing officials C03 C03 CP of legal person-senior managing official

(A) Controlling Person Type:

Code Sub-category Code Sub-category
C01 CP of legal person-ownership C08 CP of legal arrangement--trust-other
C02 CP of legal person-other means C09 CP of legal arrangement—Other-settlor equivalent
C03 CP of legal person-senior managing official C10 CP of legal arrangement—Other-trustee equivalent
C04 CP of legal arrangement-trust-settlor C11 CP of legal arrangement—Other-protector equivalent
C05 CP of legal arrangement--trust-trustee C12 CP of legal arrangement—Other-beneficiary equivalent
C06 CP of legal arrangement--trust-protector C13 CP of legal arrangement—Other-other equivalent
C07 CP of legal arrangement--trust-beneficiary C14 Unknown
(v) Specified U.S. person– A U.S person other than the following:
(a) a corporation the stock of which is regularly traded on one or more established securities markets;
(b) any corporation that is a member of the same expanded affiliated group, as defined in section 1471(e)(2) of the U.S. Internal Revenue Code, as a corporation described in clause (i);
(c) the United States or any wholly owned agency or instrumentality thereof;
(d) any State of the United States, any U.S. Territory, any political subdivision of any of the foregoing, or any wholly owned agency or instrumentality of any one or more of the foregoing;
(e) any organization exempt from taxation under section 501(a) of the U.S. Internal Revenue Code or an individual retirement plan as defined in section 7701(a)(37) of the U.S. Internal Revenue
Code;

(f) any bank as defined in section 581 of the U.S. Internal Revenue Code;
(g) any real estate investment trust as defined in section 856 of the U.S. Internal Revenue Code;
(h) any regulated investment company as defined in section 851 of the U.S. Internal Revenue Code or any entity registered with the U.S. Securities and Exchange Commission under the
Investment Company Act of 1940 (15 U.S.C. 80a-64);
(i) any common trust fund as defined in section 584(a) of the U.S. Internal Revenue Code;
(j) any trust that is exempt from tax under section 664(c) of the U.S. Internal Revenue Code or that is described in section 4947(a)(1) of the U.S. Internal RevenueCode;
(k) a dealerin securities, commodities, or derivative financial instruments(including notional principal contracts, futures, forwards, and options) that is registered as such under the laws of the
United States or any State;
(l) a broker as defined in section 6045(c) of the U.S. Internal Revenue Code; or (m) any tax-exempt trust under a plan that is described in section 403(b) or section 457(g) ofthe U.S. Internal
Revenue Code.
(vi) Owner documented FFI : An FFI meets the following requirements:
(A) The FFI is an FFI solely because it is an investment entity;
(B) The FFI is not owned by or related to any FFI that is a depository institution, custodial institution, or specified insurance company;
(C) The FFI does not maintain a financial account for any nonparticipating FFI;
(D) The FFI provides the designated withholding agent with all of the documentation and agreesto notify the withholding agent if there is a change in circumstances; and
(E) The designated withholding agent agrees to report to the IRS (or, in the case of a reporting Model 1 FFI, to the relevant foreign government or agency thereof) all of the information described
in or (as appropriate) with respect to any specified U.S. persons and (2). Notwithstanding the previoussentence, the designated withholding agent is not required to report information with respect
to an indirect owner of the FFI that holds its interest through a participating FFI, a deemed-compliant FFI (other than an owner-documented FFI), an entity that is a U.S. person, an exempt
beneficial owner, or an excepted NFE.
(vii) Direct reporting NFE
A direct reporting NFE means a NFE that elects to report information about its direct or indirect substantial U.S. owners to the IRS
(viii) Exemption code for U.S. persons
Code Sub-category
A An organization exempt from tax under section 501(a) or any individual retirement plan as defined in section 7701(a)(37)
B The United States or any of its agencies or instrumentalities
C A state, the District of Columbia, a possession of the United States, or any of their political subdivisions or instrumentalities
D A corporation the stock of which is regularly traded on one or more established securities markets, as described in Reg. section 1.1472-1(c)(1)(i)
E A corporation that is a member of the same expanded affiliated group as a corporation described in Reg. section 1.1472-1(c)(1)(i)
F A dealer in securities, commodities, or derivative financial instruments (including notional principal contracts, futures, forwards, and options) that is registered as such under the
laws of the United States or any state
G A real estate investment trust
H A regulated investment company as defined in section 851 or an entity registered at all times during the tax year under the Investment Company Act of 1940
I A common trust fund as defined in section 584(a)
J A bank as defined in section 581
K A broker
L A trust exempt from tax under section 664 or described in section 4947(a)(1)
M A tax exempt trust under a section 403(b) plan or section 457(g) plan

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