In December 2016, the Cayman Islands introduced amendments to the regulations implementing the Common Reporting Standard (CRS) in the Cayman Islands (as amended, the CRS Regulations).
The CRS Regulations require all Cayman Islands Financial Institutions to submit to the Cayman Islands Tax Information Authority (TIA) an "information notice" stating:
- The institution's name and any number given to it by the TIA as a Financial Institution;
- Whether the institution is a Cayman Reporting Financial Institution or Non-Reporting Financial Institution;
- If the institution is a Cayman Reporting Financial Institution, the type of financial institution;
- If the institution is a Non-Reporting Financial Institution, its classification under CRS;
- The full contact details of the individual that the institution has authorised to serve as the principal point of contact for the TIA; and
- The full contact details of the individual that the institution has authorised to give change notices for its principal point of contact in respect of the information stated in the information notice.
The CRS Regulations provide that the "information notice" must be submitted by 30 April 2017, or, if the entity becomes a Financial Institution after that date, by the next 30 April. However, on Friday, 3 March 2017, the Cayman Islands Department for International Tax Cooperation (DITC) announced that it will accept information notifications under the amended CRS Regulations from Financial Institutions up to 30 June 2017 without considering compliance measures or penalties. This allows Cayman Islands Financial Institutions an additional two months to ensure compliance with this regulation.
The 3 March 2017 announcement also provides that, in respect of reporting 2016 data, the TIA will not consider compliance measures or penalties against a Financial Institution that has submitted its report and such report has received an "Accepted" status by 31 July 2017. This is a two month extension from the previous deadline of 31 May 2017.
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