Acta Francisci Pp. 645

CONVENTIO

Inter Sanctam Sedem agentem etiam in nomine et ex parte Status Civitatis Vaticanae, et Foederatas Civitates Americae Septentrionalis ad substinendam adhaesionem Internationali Taxationi et complendam legem FATCA (Foreign Account Tax Compliance Act).

Agreement between the Holy See, acting Also in the Name and on Behalf of the Vatican City State, and the United States of America to Improve International Tax Compliance and to Implement FATCA

Whereas, the Holy See, acting also in the name and on behalf of the Vatican City State, and the United States of America (each, a "Party," and together, the "Parties") desire to conclude an agreement to improve international tax compliance;

Whereas, the United States of America enacted provisions commonly known as the Foreign Account Tax Compliance Act ("FATCA"), which introduce a reporting regime for financial institutions with respect to certain accounts;

Whereas, the Holy See, acting also in the name and on behalf of the Vatican City State, is supportive of the underlying policy goal of FATCA to improve tax compliance;

Whereas, FATCA has raised a number of issues, including that HS/VCS Financial Institutions may not be able to comply with certain aspects of FATCA due to domestic legal impediments;

Whereas, an intergovernmental approach to FATCA implementation would address legal impediments and reduce burdens for HS/VCS Finan- cial Institutions;

Whereas, the Parties desire to conclude an agreement to improve inter- national tax compliance and provide for the implementation of FATCA based on domestic reporting and automatic exchange, subject to the confidentiality and other protections provided for herein, including the provisions limiting the use of the information exchanged;

Now, therefore, the Parties have agreed as follows:

Article 1

definitions

1. For purposes of this agreement and any annexes thereto ("Agreement"), the following terms shall have the meanings set forth below: