2021 Cayman Islands compliance dates

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:

  • carried on intellectual property business, or
  • are claiming tax residency in another jurisdiction,

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

FAR Form

CIMA

 

31 July 2021

CRS and FATCA reporting for all Financial Institutions

Access to DITC Portal

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

CRS Compliance Form

DITC

^^ Deadline extended for this period only.

15 September 2021

CRS Compliance Form for the year ending 31 December 2020

CRS Compliance Form

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

Where Harneys provides registered office services to an entity, the Annual Return and Economic Substance Notification will be on the Harneys Connect Portal.

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.

The foregoing is for general information only and not intended to be relied upon for legal advice in any specific or individual situation.