2021 Cayman Islands compliance dates
28 Jan 2021
|
Deadline |
Filing |
Authority |
Notes |
|
15 January 2021 |
CIMA fee payments for all entities registered with CIMA |
CIMA |
Late payment penalties start to accrue after 15 January 2021 on a monthly basis |
|
15 January 2021 |
Annual declaration for directors registered with CIMA under the Director Registration and Licensing Act |
CIMA |
|
|
15 January 2021 |
Annual declaration for entities registered as a Registered Person under the Securities Investment Business Act |
CIMA |
|
|
31 January 2021 |
Economic Substance Notification |
Registrar of Companies |
This must be filed before an annual return can be filed |
|
31 January 2021 |
Annual Return and payment of annual fees for all companies and partnerships incorporated or registered in the Cayman Islands (including foreign partnerships and companies) |
Registrar of Companies |
For an entity to be considered in good standing the Annual Return and fees must be filed and paid by 31 January 2021. If the Annual Return and fees are not filed and paid by 31 March 2021 then late payment penalties start to accrue on a quarterly basis |
|
28 February 2021 |
**Economic Substance Return for entities that:
with a financial year end any time between 31 December 2019 and 29 February 2020 |
DITC |
** Deadline extended for this period only. All Economic Substance Returns for entities carrying on a relevant activity in 2020 must be filed within 12 months of the financial year end of the entity (eg. for entities carrying on a relevant activity with a financial year end of 31 December, the return for the 2020 year must be filed by 31 December 2021) |
|
30 April 2021 |
**Economic Substance Return for entities that carried on any relevant activity (except intellectual property business) with a financial year end any time between 31 December 2019 and 30 April 2020 |
DITC |
** Deadline extended for this period only. All Economic Substance Returns for entities carrying on a relevant activity in 2020 must be filed within 12 months of the financial year end of the entity (eg. for entities carrying on a relevant activity with a financial year end of 31 December, the return for the 2020 year must be filed by 31 December 2021) |
|
30 April 2021 |
Registration for entities defined as Financial Institutions under CRS and FATCA legislation that started business between 1 May 2020 and 29 April 2021 |
DITC |
|
|
30 June 2021 |
Audited financial statements for mutual funds and private funds with a financial year end of 31 December 2020 |
CIMA |
|
|
30 June 2021 |
FAR Form for funds with a financial year end of 31 December 2020 |
CIMA |
|
|
31 July 2021 |
CRS and FATCA reporting for all Financial Institutions |
DITC |
|
|
1 September 2021 |
Date by which strike off application must be submitted for an entity to be dissolved on 31 December 2021 |
Registrar of Companies |
|
|
15 September 2021 |
^^CRS Compliance Form for the year ending 31 December 2019 |
DITC |
^^ Deadline extended for this period only. |
|
15 September 2021 |
CRS Compliance Form for the year ending 31 December 2020 |
DITC |
|
|
1 November 2021 |
Date by which strike off application must be submitted for an entity to avoid 2022 fees |
Registrar of Companies |
The entity will be dissolved on 31 March 2022 |
|
1 December 2021 |
Date by which an entity must be put into voluntary liquidation to avoid 2022 fees |
Registrar of Companies |
|
|
Variable |
Economic Substance Return for entities that carried on any relevant activity during 2020 with a financial year end during 2020 (eg 31 March, 30 June, 30 September or 31 December 2020) |
DITC |
For example, an entity with a 30 June 2020 financial year end and conducting a relevant activity between 1 January 2020 and 30 March 2020 must file its economic substance return by 30 June 2021 |
|
Ongoing |
Beneficial Ownership information or exemption |
Registrar of Companies |
Entities registered with CIMA as a Registered Person under the Securities Investment Business Act or registered under the Private Funds Act or the Mutual Funds Act are not required to obtain beneficial ownership details nor maintain a beneficial ownership register, however they must file details of their exemption |
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Where Harneys provides registered office services to an entity, the Annual Return and Economic Substance Notification will be on the Harneys Connect Portal. |
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Reminder New CIMA administrative fines were introduced in 2020. These fines impact all entities licensed by CIMA or registered with CIMA, including all funds registered under the Mutual Funds Act and the Private Funds Act. Our client alert can be found here. New CIMA Rules on marketing materials and contents of offering documents that apply to both mutual funds and private funds can be found here. |
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The foregoing is for general information only and not intended to be relied upon for legal advice in any specific or individual situation.