On 31 March 2017, the Cayman Islands Gazette (Link) was issued to include (1) the list of CRS Reportable Jurisdictions (for reports due in 2017 and onwards) on page 15 as well as (2) the list of CRS Participating Jurisdictions on pages 16 and 17.
On 18 April 2017, the Cayman Department for International Tax Cooperation released an update (Link) followed by an Industry Advisory on 13 April 2017, which include the following updates:
- The AEOI Portal will be offline until “the beginning of May” due to software upgrades and updates for CRS notifications.
- Registration / Notification for CRS purposes on the AEOI Portal will begin the week of 10 May 2017, and must be completed by 30 June 2017. FATCA has also been aligned with these dates.
- The CRS reporting function on AEOI Portal is scheduled for the week of 12 June 2017.
- FATCA and CRS Reporting on 2016 accounts is due by 31 July 2017. This is also the deadline for correcting any errors with respect to reports on 2014 or 2015 accounts.
- CRS reporting must be completed with the CRS XML schema v1.0 or the manual entry form on the AEOI Portal which is based on that schema.
- Solutions are being developed to allow amended or updated return submissions in response to IRS notifications.
- A reminder that all 2016 tax year FATCA report submissions should be performed using the FATCA XML Schema v2.0 format (Link).
- A reminder that reporting under the European Union Savings Directive (“EUSD”) is not required for 2017 onwards.
With regard to UK-CDOT, the alert states the following:
- As a reminder, Reporting Financial Institutions and trustees of Trustee Documented Trusts should have completed all remediation due diligence work for Pre-Existing Accounts under UK CDOT by 30 June 2016.
- For reporting in 2017 with respect to the 2016 reporting year, a Cayman Financial Institution which has reporting obligations under UK CDOT:
- Will not be able to use the UK CDOT reporting function on the AEOI Portal.
- Must instead include in its single CRS file (i.e. whether CRS XML schema / manual entry) in respect of the UK as Reportable Jurisdiction:
- all information that would be reportable under UK CDOT; and
- if it is has reporting obligations under the CRS, any information that is reportable under the CRS with respect to the UK as Reportable Jurisdiction which are not already reported by virtue of 2.b.i above
- For reporting in 2018, onwards there will be no reporting on the basis of 2.b.i above and all reporting on UK Persons will be on the basis of 2.b.ii above.