The Cayman Islands (‘Cayman’) Department for International Tax Cooperation (‘DITC’) has issued an Industry Advisory to remind the financial services industry of the deadline for Constituent Entities (‘CE’s) in Cayman to make Country-by-Country Reporting (‘CbCR’) notifications for Multinational Enterprise (‘MNE’) Groups that have a fiscal year which began on or after 1 January 2016, and ended on or before 30 September 2018, if the MNE Group’s Reporting Entity is not resident in Cayman.

What is the 2018 CbCR deadline?

The deadline is 30 September 2018 for those Constituent Entities whose Reporting Entities are not resident in Cayman to make their CbCR Notification for those Multinational Enterprise (‘MNE’) Groups which have a fiscal year starting after 1 January 2016 and ending on or before 30 September 2018.

What happens if a CFI misses the deadline?

The DITC has advised that any Notification which is required by 30 September 2018 but not submitted by that deadline will be noted and subject to further compliance reviews.

Is the CbCR Portal open?

The Cayman CbCR Portal is open for CFIs to comply with their Notification obligations. The Reporting functions are also working and so CFIs can also comply and make their Reporting submissions using the CbCR Portal. Details of the latest advisories and information on opening times and times when the CbCR Portal may be closed may be found at the DITC’s AEOI Portal updates and Industry Advisories  page. Users should check this page on a regular basis.

How do CFIs access the CbCR Portal?

Notification is a two-part process and both Parts 1 and 2 of must be successfully submitted for the Notification to be complete.  Access to the relevant pages of the CbCR Portal may be found at the following links:

How does it work?

The DITC recommends that those looking for assistance in how to use the CbCR Portal, refer to the following documents:

CbCR Guidance v1.1   http://www.tia.gov.ky/pdf/Cayman_CbCR_Guidance.pdf  Appendix I: CbCR Notification and Appendix II: The Reporting Procedure on the CbCR Portal

More information on CbCR from Solomon Harris

For more information on the subject and on the CbCR Portal, see the following:

31 July 2018 deadline: Cayman CbCR and AEOI Portals are open; Cayman Country by Country Reporting Portal: Launch and revised guidance and documents and our earlier pieces: Country-by-Country Reporting Portal launch: grace periods and early advice; Application Of The Cayman Islands Country-By-Country Reporting Regulations To Insurance And Captive Insurance Companies and Cayman country-by-country reporting by 31 March 2018 for Multinational Enterprise Groups.)

Solomon Harris
We at Solomon Harris have been monitoring and covering the introduction of international AEOI regulations, including FATCA and the CRS and keeping a close eye on updates to the Cayman AEOI Portal. If you would like advice or assistance on any FATCA, CRS or other regulatory matters contact us on info@solomonharris.com to see how we can help.
Disclaimer
The information contained in this article is necessarily brief and general in nature and does not constitute legal advice. Appropriate legal or other professional advice should be sought for any specific matter.

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