Further to our recent advisory, Cayman Counsel Series: 2016 TIA Notification for US FATCA and UK FATCA, the Cayman Islands Tax Information Exchange Authority (TIA) has advised that they will take a soft approach to enforcement of notification and reporting due dates under US FATCA and UK FATCA for 2016.

A Reporting Cayman Islands Financial Institution (Reporting FI) for which 2015 is the first reporting period under US FATCA is required to provide a notification in respect of US FATCA on or before 10 June 2016.  If the Reporting FI is also a Reporting FI under UK FATCA, it will also be required to provide a notification in respect of UK FATCA on or before 10 June 2016.  In practice, provided that both boxes "UK" and "US" are checked when completing the AEOI Portal Notification Form, only one notification is required.

If a Reporting FI submitted a notification in respect of US FATCA last year, it is now required to submit a notification in respect of UK FATCA.  Such Reporting FIs will be permitted to log-in and edit their original notification to include UK FATCA.  This function is not yet available but is expected to be available at some point in May. 

Reports must be submitted on or before 8 July 2016 via the Cayman AEOI Portal.  Click here to access the portal. The Portal also provides access to the Cayman Islands AEOI Portal User Guide.  The User Guide (version 1.3), published on 5 April 2016, covers notification under FATCA and UK FATCA and reporting under US FATCA.  A further updated User Guide (version 2.0), which will cover reporting under UK FATCA, is under development.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.