FATCA Policy

This FATCA Policy outlines Berdain LLP's ("Berdain LLP," "we," "us," or "our") commitment to complying with the Foreign Account Tax Compliance Act (FATCA) of the United States. FATCA is a U.S. federal law enacted to combat tax evasion by U.S. persons holding financial assets in non-U.S. financial institutions.

1. What is FATCA?

FATCA was enacted in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act. It requires Foreign Financial Institutions (FFIs) to report information about financial accounts held by U.S. persons, or by foreign entities in which U.S. persons hold a substantial ownership interest, to the U.S. Internal Revenue Service (IRS).

To facilitate FATCA compliance, the U.S. Treasury Department has developed Intergovernmental Agreements (IGAs) with various countries. These IGAs simplify compliance for FFIs in participating jurisdictions and allow for information exchange between the U.S. and partner governments.

2. Berdain LLP's Commitment to FATCA Compliance

Berdain LLP is committed to full compliance with FATCA and any applicable Intergovernmental Agreements (IGAs) between the United States and the jurisdictions in which we operate or facilitate services. Our compliance framework is integrated into our client onboarding and ongoing monitoring processes.

3. Scope of this Policy

This policy applies to all clients of Berdain LLP, including individuals and entities, and covers all services that may involve financial accounts or assets, such as:

• Company Formation
• Offshore Banking Assistance
• Merchant Account Setup
• Accounting & Reporting
• Nominee Director Services
• Corporate Secretary Services

4. Identification of U.S. Persons

As part of our due diligence and client acceptance procedures, Berdain LLP is required to identify whether a client, or any controlling person or beneficial owner of a client entity, is a "U.S. Person" for FATCA purposes. A "U.S. Person" generally includes:

• A U.S. citizen (even if residing outside the U.S.).
• A U.S. resident alien (Green Card holder or meeting the substantial presence test).
• A domestic partnership, corporation, trust, or estate.

5. Client Obligations

To enable Berdain LLP to comply with its FATCA obligations, clients are required to:

5.1. Provide Self-Certification:

Complete and sign relevant self-certification forms (e.g., IRS Form W-9 for U.S. Persons, or appropriate W-8 forms for non-U.S. Persons) upon onboarding and periodically as requested. These forms declare your U.S. tax status.

5.2. Provide Supporting Documentation:

Furnish any additional documentation requested by Berdain LLP to verify your U.S. or non-U.S. tax status, including but not limited to tax identification numbers (TINs), passports, and proof of residency.

5.3. Notify of Changes:

Promptly notify Berdain LLP in writing of any change in circumstances that may affect your U.S. tax status or the U.S. tax status of any controlling person or beneficial owner of an entity for which we provide services. This includes changes in citizenship, residency, or other relevant information.

5.4. Consent to Disclosure:

By engaging our services, you acknowledge and consent to Berdain LLP disclosing your information, including personal and financial data, to relevant tax authorities (e.g., IRS, local tax authorities under IGA) if you are identified as a U.S. Person or if required by law.

6. Berdain LLP's Actions and Reporting

If a client or an entity's controlling person/beneficial owner is identified as a U.S. Person, Berdain LLP will:

• Collect Required Information: Obtain all necessary information, including U.S. Taxpayer Identification Numbers (TINs).
• Report to Authorities: Report the required information to the relevant tax authorities in accordance with applicable IGAs or direct reporting requirements. This may include account balances, interest, dividends, gross proceeds, and other income.
• Withholding: In certain circumstances, if a client fails to provide the necessary FATCA documentation or is identified as a non-compliant U.S. account holder, Berdain LLP or associated financial institutions may be required to withhold a percentage of certain payments made to the client.

7. Consequences of Non-Compliance by Client

Failure to comply with Berdain LLP's requests for FATCA documentation or information may result in:

• Refusal of Services: Berdain LLP may decline to provide or continue providing services.
• Termination of Services: Existing service agreements may be terminated.
• Reporting to Authorities: Berdain LLP may be required to report the client as a "non-consenting" or "recalcitrant" account holder to the relevant tax authorities, potentially leading to adverse consequences for the client, including penalties imposed by the IRS.
• Withholding of Payments: Financial institutions may be required to withhold taxes on payments made to the client.

8. Disclaimer

This FATCA Policy is for informational purposes only and does not constitute tax or legal advice. Clients are strongly advised to seek independent professional tax advice regarding their FATCA obligations and U.S. tax status.

9. Changes to This Policy

Berdain LLP reserves the right to modify or update this FATCA Policy at any time to reflect changes in FATCA regulations, IGAs, or our internal compliance procedures. Any changes will be effective immediately upon posting on our website. We encourage you to review this policy periodically.

10. Contact Us

If you have any questions about this FATCA Policy, please contact us at: