Cayman Islands: FATCA and CRS reporting deadline extended to 31 July 2018

Cayman Islands reporting financial institutions (FIs) have been given until 31 July 2018 to complete their FATCA and CRS reporting for the 2017 calendar year without the fear of further action by government authorities, the Cayman Islands government announced yesterday.

The AEOI reporting portal will close on 1 June 2018, as expected, and the government currently intends to re-open it on 15 June until 31 August 2018, to give FIs more time to complete their reporting obligations.

Although the statutory deadline for FATCA and CRS reporting remains 31 May 2018, provided that FIs have completed their reporting on or before 31 July 2018, no compliance or enforcement measures will be taken or penalties applied for late filing.

FIs that fail to meet the 31 July deadline (even though the government currently intends that the portal will be open until the end of August), may be subject to compliance reviews by the Cayman Islands Department for International Tax Cooperation.

FIs with CRS reporting obligations are reminded that they must file a ‘nil return’ for all CRS reportable jurisdictions even if they have no reportable accounts in those jurisdictions. Although not mandatory, Harneys recommends that FIs file ‘nil returns’ in respect of their FATCA reporting if they have no US Reportable Accounts.

Key dates

12 noon (Cayman time), 1 June 2018: AEOI portal closes

15 June 2018: AEOI portal expected to re-open

31 July 2018: 2017 FATCA and CRS reporting must be completed to avoid penalties / enforcement measures

31 August 2018: AEOI portal expected to close

Please contact your usual Harneys contact if you would like advice on any aspect of the AEOI regime in Cayman and how to comply with it or if you have any other questions or visit www.harneys.com/Cayman.