In our alert "
FATCA Notification and Reporting – Are you ready?"
we reported that Cayman Islands Financial Institutions
("Cayman Islands FIs") must notify the Cayman Islands Tax
Information Authority, Department for International Tax Cooperation
("TIA") on or before 30 April 2015 and report on U.S.
Reportable Accounts on or before 31 May 2015.
Cayman Islands FIs should be aware of the following new
(i) the Cayman Automatic Exchange of
Information Portal (AEOI Portal) is now OPEN;
(ii) the TIA has issued an AEOI Portal User Guide which includes
helpful information on how to notify and report; and
(iii) Cayman Islands FIs who do not have any Reportable Accounts
are no longer required to mandatory report to the TIA on a NIL
report basis, but the requirement to notify the TIA by 30 April
2015 still applies.
Notifications (i.e. registrations) and reporting may be
conducted by or on behalf of Cayman Islands FIs directly to the TIA
via the AEOI Portal.
AEOI Portal User Guide
The TIA has published a User Guide for the AEOI Portal in order
to assist Cayman Islands FIs making filings. The User Guide can be
accessed through the following link here.
Cayman Islands FIs are required to complete a notification form
on the AEOI Portal. When completing the AEOI notification form, the
Cayman Islands FI is required to upload a pdf letter on letterhead
(if possible) identifying and providing authorisation for a third
party provider or individual to be assigned as the principal point
of contact on behalf of that Cayman Islands FI. The letter should
include at a minimum: the Cayman Islands FI name, GIIN, full name
and business contact details of the person providing the
authorisation, along with the full name and office address of the
principal point of contact.
NIL Return Reporting Non-Mandatory
Cayman Islands FIs who do not have any Reportable Accounts are
no longer required to mandatory report to the TIA on a NIL report
basis. This means that only Cayman Islands FIs with U.S. Reportable
Accounts will be required to report to the TIA on or before 31 May
However, please note that Cayman Islands FIs with no
U.S. Reportable Accounts are still required to complete the
notification form on the AEOI Portal by 30 April 2015.
For further guidance on FATCA please contact us.
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.
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