Cayman Islands reporting Financial Institutions (FIs) have been given until 31 July 2019 to complete their FATCA and CRS reporting for the 2018 calendar year without the fear of further action by government authorities, the Cayman Islands government announced last week.
Although the statutory deadline for FATCA and CRS reporting remains 31 May 2019, provided that FIs have completed their reporting on or before 31 July 2019, no compliance or enforcement measures will be taken or penalties applied for late filing. FIs that fail to meet the 31 July deadline, may be subject to compliance reviews by the Cayman Islands Department for International Tax Cooperation.
There has been no change to the notification deadline, which remains 30 April 2019. This deadline applies to all new FIs since 2018.
FIs are urged to file all returns (including those outstanding from years 2014 through 2017) as soon as practicable as access to the AEOI portal may be affected by increased activity closer to the filing deadline.
FIs with CRS reporting obligations are reminded that, in addition to any reportable jurisdiction returns filed, they must file a ‘nil filing declaration’ in order for their obligations to be fully discharged. Although not mandatory, Harneys recommends that FIs file ‘nil returns’ in respect of their FATCA reporting if they have no US Reportable Accounts as positive proof of compliance with the FATCA regulations.
The Cayman Islands government also confirmed that there has been no change to the CRS Reportable Jurisdiction list from that issued on 1 February 2018 which can be found here.
30 April 2019: Notification deadline for all new Reporting FIs
31 July 2019: 2018 FATCA and CRS reporting must be completed to avoid penalties / enforcement measures
Please contact Hazel O'Brien or your usual Harneys contact if you would like advice on any aspect of the AEOI regime in Cayman and how to comply with it or if you have any other questions or visit www.harneys.com/Cayman.