Cayman Islands: CRS compliance form deadline

The annual deadline will be 15 September.

The annual deadline will be 15 September.

The Cayman Islands tax authority in April 2020 updated common reporting standard (CRS) regulations requiring reportable financial institutions (tax residents in the Cayman Islands) to provide additional information annually to the tax authority in order to comply with the reporting and due diligence requirements as required under the CRS.

This additional information is required to be reported on the new CRS compliance form and will be required for reporting years FY 2019 onward. The forms will be completed via the Department for International Tax Cooperation (DITC) Portal (the same mechanism as the annual CRS reporting).
 

Required entities

All Cayman reportable financial institutions, with the exception of investment managers and advisers, are required to submit the annual CRS compliance form.
 

Deadline

The annual deadline will be 15 September. However, in its initial year of reporting, both FY 2019 and FY 2020 CRS compliance forms will be due by 15 September 2021. An extension has not been made as of 24 August 2021.
 

Requirements

Information to be collected will revolve around the following key points:

  • Financial institution profile data. Section 1 covers the financial institutions’ logistical and licensing information. Reporting financial institutions licensed with the Cayman Islands Monetary Authority (CIMA) will have to update the form in this section with the CIMA license number, and may skip Section 3. If the financial institution was a reportable financial institution in both FY 2019 and FY 2020 reporting years, but did not obtain the license number until calendar year 2020, then the financial institution compliance form is to be marked “no” for FY 2019 and “yes” for FY 2020.
  • Financial account data. Section 2 dives into the total numbers of reportable versus nonreportable account holders, and the values of the financial institutions broken down into those of reportable and nonreportable accounts. Thus, even if CRS nil returns were submitted for the reporting years, completion of the compliance form is still required. Any mismatches between the compliance form and the filed CRS annual returns may trigger an inquiry from the DITC.
  • AML / KYC and accounting. Section 3 is a short section with administrative questions regarding outsourced service providers and anti-money laundering (AML) / know-your-client (KYC) procedures. As previously mentioned, if the financial institution is licensed with CIMA, this section is not required.
  • CRS process. Section 4 further covers administrative aspects of the financial institution's obligations including due diligence and health checks along with confirmation of the financial institution's obligation to maintain written policies and procedures, as set out under the CRS legislation.

Submission

The submission of the CRS compliance form is to be made, similar to the annual CRS return, via the DITC Portal. The submission can be completed by the financial institution's “principal point of contact” (PPoC) or an assigned secondary user.

There are two options for submission:

  • Smart form
  • Bulk-upload CSV file

The long-awaited bulk-upload option may be beneficial for entities with a few financial institutions in their structure. The option to submit the CSV file in the DITC Portal is live as of 25 August 2021. There are some anticipated errors for this new option, and the DITC released a set of “frequently asked questions” (FAQs) to address the issues.

The Cayman CRS compliance form is mandatory for reporting years FY 2019 onward. 

 

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