How Offshore AP and Shared Services Teams Run IRS TIN Matching

Vendor onboarding moved offshore. IRS access did not. Accounts payable, vendor master maintenance and 1099 preparation now run from centers in Mexico, India, the Philippines and Costa Rica, staffed by people who usually have no SSN or ITIN. With TIN Comply, the US company owns the account and adds those staff as users, so the matching gets done and the record stays with the payer.

The Problem

US companies and the outsourcing firms that serve them run a large share of vendor onboarding, AP and year-end 1099 work from shared services centers outside the United States. The work is the same as it was in Dallas or Columbus: collect the W-9, confirm the name and TIN, set the vendor up, file the return. What changed is who is doing it.

IRS systems were not built around that arrangement. The IRS said as much in e-News for Withholding Agents, Issue 2026-04 (May 4, 2026), noting that certain foreign filers "may be unable to obtain an SSN or ITIN for their authorized users." That bulletin is about the IRIS filing system rather than TIN Matching, but the practical issue is the same across IRS programs: the people doing the work often cannot be the people holding the IRS credential.

The result, in most shared services setups, is one of three workarounds. A US employee runs the matches in batches when they have time. The offshore team skips matching and files on the W-9 alone. Or a shared login gets passed around, which fails the first audit question about who did what.

How It Works in TIN Comply

TIN Comply runs IRS TIN matching for the payer, so nobody on the offshore team needs an IRS login of their own.

The US payer or its authorized agent owns the account. The company that files the 1099s, or the agent filing on its behalf, holds the TIN Comply account and is the party the matching is performed for.

The admin adds users wherever they sit. Under Admin, the account owner adds each team member with their own login, in Monterrey, Pune, Manila or San Jose. Admin rights are assigned or revoked per user, two-factor authentication can be required, and an account can be disabled the day someone leaves. There is no shared password and no credential to hand back.

Every match is attributed and timestamped. Each validation lands in the account's history with who ran it, when, and the result, whether it was run one at a time in the portal, as a bulk file, or through the API from the team's own system. The record belongs to the account, not to the person who clicked.

The audit file exports from the account. When a 972CG notice or an internal review asks whether a vendor was matched before payment, the answer is a filtered export from the history, not a reconstruction from an inbox in another time zone.

What Stays the Same

Moving the work does not move the obligation. IRS TIN Matching exists for payers and their authorized agents who prepare information returns, and results may be used only for that purpose. The US payer is still the filer, still responsible for the name and TIN on every return, and still the party a CP2100 or 972CG notice is addressed to. The offshore team is doing the payer's work inside the payer's account.

Who Uses This Setup

  • Finance shared services centers of US companies that handle vendor onboarding and AP for the whole group from one location abroad.
  • AP and procure-to-pay outsourcers running vendor setup and 1099 preparation for US clients.
  • Accounting and tax firms' delivery centers doing US information-return work for client engagements, where each match has to be tied to the right client.

In each case the pattern is the same: the US entity (or the agent) owns the account, the delivery team works inside it, and the record never leaves it.

Checklist for the US Account Owner

  1. Decide who owns the account. The payer, or the authorized agent filing for it. The owner holds the admin rights.
  2. Add users by name, one login each. No shared credentials. Turn on two-factor authentication.
  3. Know which entity each match is for. Agents serving several clients should keep each client's matching separable, by account or by the client identifier on the request, so the audit file for one client does not contain another's vendors.
  4. Remove people the day they leave. Disable the user; the history they created stays in the account.
  5. Export results into the audit file at the end of each onboarding cycle and before filing, so the proof of matching sits with the 1099 records rather than in the tool alone.
  6. Confirm your data-transfer policy covers vendor names and TINs being viewed from the countries where your team works.

Getting Started

The account works the same way whether the team is across the hall or across an ocean. Start a free trial and add your first offshore user, or request a demo to walk through a shared services setup with several entities or clients.

For how the IRS program itself works, who may use it, and what each result code means, see the IRS TIN Matching guide on tincompliance.com.

This article is for informational purposes only and does not constitute legal or tax advice. Check your own data-transfer and vendor-data policies before giving users outside the United States access to vendor records.

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