Updates on Cayman Islands' CRS and FATCA reporting: Mandatory date of birth submission and 2023 reporting deadlines
In March 2024, the Cayman Islands' Department for International Tax Cooperation (DITC) issued a bulletin containing important updates regarding the Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) reporting requirements.
Regarding CRS missing dates of birth
The DITC reviewed data submitted for the 2022 reporting period and found that approximately 10 percent of Financial Institutions (FIs) failed to report a date of birth (DoB) for individual Account Holders and/or Controlling Persons.
It is emphasised that reporting the DoB is mandatory for all individuals who are Reportable Persons, as per regulations. Even though the CRS XML schema labels the DoB element as "(Optional) Mandatory," FIs are required to include it if the information is available in their records.
FIs are reminded of their Anti-Money Laundering (AML) obligations to collect valid identification including DoB, thus it is expected they have this information.
FIs are also urged to ensure correct DoB is provided for all relevant parties in CRS XML Returns for the 2023 reporting period, with a deadline of 31 July 2024. Failure to comply may lead to enforcement action.
Regarding 2023 CRS & FATCA reporting deadlines
The DITC Portal is open for uploading 2023 CRS and FATCA XMLs.
Deadlines are as follows:
- Registration (Notification): 30 April 2024
- 2023 CRS Reporting: 31 July 2024
- 2023 CRS Filing Declaration (Nil return): 31 July 2024
- 2023 FATCA Reporting: 31 July 2024
- 2023 CRS Compliance Form: 16 September 2024 (extended from 15 September 2024 due to it being a Sunday)
DITC’s updates bulletin can be accessed here.
