Within moments of the circulation of Appleby's eAlert
Cayman AEOI Portal Almost Open," the Cayman
Islands Tax Information Authority followed through: the Portal is
now indeed open.
Cayman Islands reporting financial institutions
(Reporting FIs) are required to use the Portal to
file the reports required pursuant to the Tax Information Authority
(International Tax Compliance) (United States of America)
(Amendment) Regulations, 2015 and the Tax Information Authority
(International Tax Compliance) (United Kingdom) (Amendment)
Regulations, 2015 (Regulations). It is expected
that the Portal will also accommodate filings under the OECD's
Common Reporting Standard (CRS) once in
Step 1: Cayman AEOI Portal Initial Set Up
The first step to using the Portal is for the Reporting FI to
complete the necessary form to set up an account. To do this, go to
the Department of International Tax Cooperation website [ www.tia.gov.ky ],
select "Automatic Exchange of Information"
(AEOI) from the side bar, then click on
"Cayman AECI Portal Initial Setup (Notification)". After
a security check, the Reporting FI will be presented with an online
form requesting basic information, including its name, email
address, GIIN number, category of FI, and confirmation of whether
it is subject to the US or UK Regulations, or both. A principal
point of contact (POC) must be named and a PDF
document attached authorising the POC to act on behalf of the
Reporting FI. More information on the POC is contained in our
Upon submission of the online form, the Reporting FI will
receive a username and temporary password to access the Portal. The
POC will want to adopt a new password when first accessing the
Note that the Reporting FI must complete its initial set up on
the Portal by 30 April 2015.
Step 2: US Reporting Requirements
The US Regulations require that the first reports be filed no
later than 31 May 2015. This first report is in respect of
individual accounts held by US Specified Persons that were opened
between 1 July 2014 and 31 December 2014.
The next deadline is 30 June 2015 in respect of pre-existing
high value individual accounts (ie individual accounts that were
already in existence on 30 June 2014 and which had a balance or
value that exceeded US$1,000,000 as at 30 June 2014).
If the Reporting FI has carried out a review and classification
process on any of its pre-existing individual accounts that are low
value (ie an account that had a balance or value of less than
US$1,000,000 on 30 June 2014) and any pre-existing entity accounts
(ie those in existence on 31 December 2014 with a balance or value
that exceeds US$250,000), those can also be reported as part of
this reporting cycle but the deadlines for those reviews and
reports are as follows:
Pre-existing low value individual – 30 June 2016
Pre-existing entity accounts – 30 June 2016
The Portal permits the Reporting FI to enter the data manually
in an online template, or the information can be uploaded as an
attachment in XML format following the IRS Schema. The data
required in respect of each reportable account are:
Tax identification number
Name of the Reporting FI
GIIN of the Reporting FI
The account balance or value as at 31 December 2014 (or
immediately prior to its closure if the account was closed during
the reporting period)
Further Reporting Requirements
Reporting under the UK Regulations will commence in 2016 and
under the CRS in 2017. Appleby will advise when those deadlines
Note that under the US Regulations, this first reporting period
is treated as something of a 'soft launch': in future
reporting, additional information may have to be reported depending
on the nature of the account.
Update to the Regulations
The Ministry of Financial Services has also announced that it
has received Cabinet approval to amend the mandatory nil return
requirements in the Regulations. Currently, the Regulations require
that a Reporting FI with no reportable accounts must report that
fact via the Portal in each calendar year. Under the amended
Regulations, it will not be mandatory for the Reporting FI to
submit nil returns annually. However, Cayman Reporting FIs with no
reportable accounts will still need to complete the notification
requirement using the Portal.
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