The Department for International Tax Cooperation wishes to advise Industry:

A. Extended 2017 deadline for new Notification (Registration) and Variation of Reporting (Notification) Obligations for US FATCA/CRS

ALL Cayman Financial Institutions (CFIs) must register, or vary their existing US FATCA/UK CDOT registration, for CRS on the AEOI Portal, even if they have no reporting obligations. PPoCs must access the Portal to ensure all necessary notifications have been completed. The deadline for completion of the registration/variation process is 31 July 2017. All reporting CFIs and Trustee Documented Trusts must also submit a CRS Filing Declaration, even if they have no reportable accounts. Any CFIs that have not already registered on the AEOI Portal or varied their US FATCA/UK CDOT registration MUST ensure that they do so urgently to ensure compliance with Cayman law*. High levels of traffic on the Portal may cause delays.

B. Final Extension of 2017 Reporting Deadline for US FATCA & CRS

The deadline for US FATCA/CRS reporting this year has been extended to 31 August 2017. This is a final extension and no further extensions will be given. CFIs with reporting obligations MUST proceed to submit their reports as soon as possible. All reporting CFIs and Trustee Documented Trusts must submit a CRS Filing Declaration, even if they have no reportable accounts. High levels of traffic on the Portal may cause delays. It is therefore highly advisable for CFIs to perform their obligations with urgency to ensure compliance with Cayman law*. The AEOI Portal will be taken offline at 4:00pm on 31 August 2017 so that the DITC can prepare for transmission of CRS Returns to the OECD Common Transmission System by 30 September 2017.

*A CFI’s obligation to notify the Department for International Tax Cooperation of the required information to the deadlines advised is enacted in Cayman law through the 2016 amendments to Regulation 8 of the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015. A CFI commits an offence if it does not fulfil these obligations and may be fined up to KYD50,000. The representatives, for example directors, of a CFI may be held liable for contraventions of the Regulations if proof of reasonable diligence cannot be provided.