On 15 April 2020 the Cayman Islands Department of International Tax Compliance (“DITC”) released a new CRS Compliance Form, a mandatory filing required as part of your compliance with the Common Reporting Standard (“CRS”). The CRS Compliance Form is part of the ongoing assessment by the Global Forum’s AEOI Peer Reviews to review CRS implementation effectiveness; the review will be published in 2021. By implementing the CRS Compliance Form the Cayman Islands can show the effectiveness of its implementation of CRS.
The CRS Compliance Form requires Cayman Islands Reporting Financial Institutions to collect information for the following sections and submit the form via the DITC Portal which will be available in June 2020:
Financial Institution Data Profile.
Financial Account Data, including information and classification of type of Non-Reportable Accounts.
AML/KYC and Accounting (where applicable).
CRS Due Diligence Process.
The deadline for the submission of this form will be 15 September each year. To provide enough time to collect the information and complete the form, the deadline for the 2019 reporting period will be 31 December 2020. The DITC will apply automatic penalties where this deadline is not met.
FATCA REPORTING DEADLINE EXTENSION
The DITC is extending the FATCA deadline to 16 November 2020, following the recent announcement by the IRS to extend the exchange of information deadline for Model 1 jurisdictions for the 2019 reporting, .
Please note that the CRS reporitng deadline will remain 18 September 2020.
As FATCA and CRS reporting is becoming more demanding, including the announcement of the new CRS form, we have seen a strong interest from our global client base to delegate their AEOI function to a third party that has the resources and expertise to ensure full compliance. As the filing deadlines approach, we welcome the opportunity to further discuss our compliance solutions, along with any new requirements you may have.