Tax ID in the Marshall Islands: Banking, CRS, and FATCA

Does the Marshall Islands Issue a Tax ID? The Short Answer for Foreign OwnersCopy link to section

The Marshall Islands does not issue Tax Identification Numbers in the conventional sense. For taxpayer identification it relies on Employer Identification Numbers (EINs) administered by the Marshall Islands Social Security Administration, and those numbers arise only when a company has employees within the jurisdiction. The Marshall Islands tax ID question, for a foreign-owned entity, therefore has a clear answer: there is no local TIN to obtain, because there is no domestic income tax obligation that would call for one.

This matters most to non-resident owners of International Business Companies and to their advisers, who will encounter the missing-TIN issue when opening bank accounts, completing self-certifications, or responding to a foreign tax authority. The pages that follow explain why the number does not exist, which identifiers do, and how to satisfy counterparties who expect one. The OECD's own TIN guidance records this position in writing, which is the document you will most often need to cite.

The Marshall Islands Tax System Context: Why a Conventional TIN May Not ApplyCopy link to section

The jurisdiction operates a territorial tax system, meaning only income earned within its borders falls inside the local tax net. Companies formed under the Business Corporations Act as Non-Resident Domestic Entities are exempt from local taxation entirely, provided they conduct no business onshore.

A Non-Resident Domestic Corporation pays no corporate income tax, no capital gains tax, and no withholding tax on dividends, interest, or royalties paid abroad. Estate, gift, and stamp duties do not reach international transactions either.

Because such an entity carries no corporate income tax obligation, the government has no reason to issue or maintain a tax number for it. The absence of a TIN is a structural feature of the zero-tax regime, not an administrative gap.

The country has also concluded only a limited number of double taxation treaties. No broad treaty network exists that would require cross-border TIN infrastructure for non-residents, which reinforces the same conclusion from a different direction.

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Identifiers That Do Exist: Entity Registration Numbers from the Registrar of CorporationsCopy link to section

Every company formed in the jurisdiction receives an entity registration number at incorporation, and this is its primary official identifier. The number appears on the Certificate of Incorporation and on any Certificate of Good Standing.

The Companies Registry handles incorporation and ongoing maintenance, with administrative and technical support provided by International Registries, Inc. (IRI). IRI operates through a network of 28 offices worldwide, any of which can form companies and service clients.

The registry is "closed." A standard search returns the entity's legal name, registration number, incorporation date, current standing, and the name and address of both the registered agent and registered office, but directors and shareholders stay private unless the company elects to file them.

Companies must keep a register of beneficial owners, but that record is held at the company's own office and is not open to the public. You can confirm an entity's details through the official entity search maintained by IRI.

Tax ID for Non-Resident Domestic Companies and IBCs: What to ExpectCopy link to section

An EIN obligation attaches to employment activity, not to incorporation. A company that conducts no local business and hires no resident employees has no requirement to register with the Social Security Administration and therefore receives no EIN.

Hiring even a single resident employee changes this. At that point the firm must apply to the Social Security Administration for an EIN, with an application fee of USD 20 for corporations.

The EIN format is distinctive: an employer number begins with a five-digit figure and ends in "04" with a dash between them, such as 08612-04, while an employee number begins with "04" followed by a six-digit figure. The "04" is a country code assigned by the United States to the freely associated states.

Non-resident companies file no annual financial statements, audit reports, or income tax returns with the government. There is no public filing requirement comparable to Companies House or the SEC.

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How a Missing or Substitute Tax ID Affects Bank Account OpeningCopy link to section

Few banks operate locally, so most non-resident companies bank offshore, often in centres such as Singapore or Hong Kong. Account opening commonly takes two to six weeks, though it can run to several months depending on the banking jurisdiction, the readiness of your documents, and the compliance review.

Initial deposit requirements vary from around USD 1,000 for a standard corporate account to USD 100,000 or more for premium banking. The jurisdiction's low-tax reputation means even banks willing to onboard its entities apply lengthy and detailed due diligence.

During KYC and AML checks, banks treat the IRI corporate registration number as the company's primary identifier. An EIN would appear on official documents only where one exists, which is to say only where the company employs resident staff.

When a bank's system contains a mandatory TIN field and your entity has none, the accepted approach is to enter the corporate registration number and attach a short written explanation that the jurisdiction does not issue TINs to non-resident entities. Most compliant banks accept this with supporting documentation.

Completing CRS and FATCA Self-Certification Without a Local TINCopy link to section

The Marshall Islands signed the CRS Multilateral Competent Authority Agreement on 29 October 2015, and automatic exchange of information began in September 2018. Although foreign-source income is not taxed locally, the jurisdiction participates fully in the exchange framework.

Under that arrangement, banks holding accounts linked to local entities report balances, interest, and dividends to the local authority, which passes the data to the country where the beneficial owner is tax resident. The company's ownership may stay private, but financial account information moves automatically to the owner's home jurisdiction.

OECD self-certification forms anticipate the missing-TIN situation by offering three permitted reasons:

• Reason A — the jurisdiction does not issue TINs to its residents
• Reason B — the account holder is otherwise unable to obtain a TIN
• Reason C — no TIN is required

A non-resident entity with no local tax nexus should select Reason A and supply the beneficial owner's home-country TIN instead, since the report flows to that owner's country of residence.

On the FATCA side there is no Intergovernmental Agreement with the United States. As a result, financial institutions in the jurisdiction register directly with the IRS as Foreign Financial Institutions rather than reporting under an IGA umbrella; the US Treasury maintains the IGA status list confirming this position.

Note one related point: the Registrar may ask an entity claiming foreign tax residency for a tax identification number or a tax residence certificate, which becomes relevant where the company seeks an economic substance exemption on the basis of being tax resident elsewhere.

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Tax ID Requirements When Dealing with Foreign Authorities and Treaty FormsCopy link to section

When a foreign tax authority or counterparty requests a TIN on a treaty form such as the US Form W-8BEN-E, document that the jurisdiction does not issue TINs to non-resident entities and provide the corporate registration number as the closest functional equivalent. The same applies to any treaty-relief request, though with no FATCA IGA, no Competent Authority Agreement, and no US Chapter 3 relief available, treaty benefits will rarely be in play.

The absence of local filing duties does not erase obligations at home. Controlled Foreign Company rules, FBAR reporting, and home-country foreign income rules apply according to the owner's tax residency, not according to local requirements.

For non-US owners, the larger exposure usually comes from CFC legislation in their own country. Most EU member states, the United Kingdom, Australia, and Canada operate rules that can attribute offshore income directly to a controlling individual.

US persons holding such entities must continue to file information returns such as Form 5471 or Form 8858 along with FBAR disclosures. On those forms the IRI registration number, not a local TIN, identifies the entity.

Distinguishing Registration Numbers, Business Licenses, and Tax IdentifiersCopy link to section

Several numbers circulate in this jurisdiction, and confusing them is a frequent source of error in KYC files. The table below separates each identifier by issuer, function, and the entities it applies to.

The EIN functions as the local equivalent of a taxpayer number, but only once employer obligations arise. Issuing a registration number is a corporate law function, not an act of tax administration, which is why it carries no tax meaning. No VAT or sales tax registration number exists either, since those taxes do not apply to offshore activity.

Practical Steps If a Counterparty Insists on a Marshall Islands Tax IDCopy link to section

Some counterparties treat a TIN field as non-negotiable. The following sequence resolves almost every such request.

1. Produce the OECD TIN guidance. The jurisdiction's own submission, published on the OECD CRS portal, states in writing that it does not issue TINs and uses employer EINs as the functional equivalent only for employers.
2. Supply the IRI corporate registration number. This is the primary identifier, shown alongside the legal name and incorporation date on the official registry extract.
3. Provide a Certificate of Good Standing. Issued by IRI, it confirms the company is active, has met its annual formalities, and has paid all required government fees.
4. Select Reason A on CRS self-certification. The OECD standard form expressly allows this where the jurisdiction does not issue TINs to its residents.
5. Provide the beneficial owner's home-country TIN. Because reporting flows to the owner's country of tax residence, that number satisfies the substance of what the counterparty needs.
6. Supply the MISSA EIN if one exists. Where the company employs resident staff, give the number (format XXXXX-04) with a brief note on its scope.
7. Keep a foreign tax residence certificate on file. Obtaining one from the owner's home jurisdiction supports both an economic substance exemption claim and bank KYC at the same time.

Outlook: Will the Marshall Islands Introduce a Formal Tax ID Regime?Copy link to section

No government announcement, legislative proposal, or OECD or EU roadmap item requiring a formal TIN regime for non-resident entities has been identified. Several factors point toward the position holding.

The jurisdiction was removed from the EU list of non-cooperative tax jurisdictions on 17 October 2023, following its economic substance commitments, which suggests reform pressure was satisfied without a TIN regime. The EU's updated list, effective 10 October 2025, contains 11 countries and does not include the Marshall Islands; the EU Council maintains the current list.

Even after adopting economic substance requirements, the principle of zero taxation on foreign income has stayed intact. The economy rests on registration fees rather than taxation, a model stable for decades, and a TIN regime would demand a domestic tax administration that does not exist for non-resident entities.

Participation in CRS since 2018 also reduces any external pressure, since information exchange already runs through financial institutions rather than a domestic TIN system.

ConclusionCopy link to section

For a foreign-owned non-resident entity, the missing tax ID is a feature of the regime rather than a problem to solve. The corporate registration number from IRI serves as your primary identifier, the beneficial owner's home-country TIN covers CRS reporting, and the OECD guidance document settles most counterparty objections. What deserves your attention is not the absent local number but the live reporting and CFC obligations in the country where you or your owners are tax resident.

How Expanship Can Help Your Business in Marshall IslandsCopy link to section

Expanship handles the documentation that resolves a missing-TIN request, from securing your corporate registration number and Certificate of Good Standing to preparing the CRS and FATCA self-certifications and supporting bank KYC files, and supports the full lifecycle of a non-resident entity beyond that.

• Forming your Non-Resident Domestic Company or IBC and obtaining incorporation documents
• Acting as registered agent and providing a registered office
• Managing tax registration where employer obligations arise and handling related filings
• Maintaining ongoing compliance, including economic substance and beneficial ownership records
• Keeping accounting and bookkeeping in order for reporting at the owner's level
• Introducing you to banks experienced with non-resident entities

To discuss your situation, contact Expanship Marshall Islands.

Frequently Asked QuestionsCopy link to section