FATCA REPORTING PORTAL OPEN
On 19 March 2015, the Cayman Islands Tax Information Authority ("TIA") launched its online portal for the automatic exchange of tax information (the "AEOI Portal"), which can be accessed from TIA's website (www.tia.gov.ky).
AEOI PORTAL USER GUIDE
A user guide to the AEOI Portal is available on TIA's website and is accessed by clicking on "AEOI News & Updates".
REPORTING FIS TO REGISTER WITH TIA BY 30 APRIL 2015
Reporting Cayman Islands Financial Institutions ("Reporting FIs") must register with TIA by 30 April 2015. The registration portal can be accessed from TIA's website by clicking on "Cayman AEOI Portal Initial Setup (Notification)". To register, the Reporting FI must provide the following information:
- If the Reporting FI is required to report under UK and/or US FATCA (in most cases, both will apply)
- GIIN (the FATCA registration number provided by the IRS)
- FI categorisation (eg. Investment Entity)
- Principal point of contact (together with a pdf letter on the Reporting FI's letterhead evidencing the person's authorisation).
REPORTING FIS TO REPORT TO TIA BY 31 MAY 2015
Reporting FIs are required to report to TIA by 31 May 2015 on any US Reportable Accounts for the 1 July – 31 December 2014 period. Reporting FIs are not required to report on any UK Reportable Accounts until next year. Reports can be submitted by uploading files in XML format or by manually entering data. The reporting portal can be accessed from TIA's website by clicking on "Cayman AEOI Portal Login (Reporting)". Reporting FIs must submit the following information on each US Reportable Account:
- Tax Identification Number
- Account number (or functional equivalent)
- The Reporting FI's GIIN
- Account balance or value (in US$ or the currency in which the account is denominated) at 31 December 2014 or immediately prior to closure (if closed during the 1 July – 31 December 2014 period)
NIL REPORTS NOT REQUIRED
Significantly, we understand that TIA is no longer requiring nil reports to be submitted, although a Reporting FI may submit nil reports if it wishes to do so. It may be in a Reporting FI's interests to submit nil reports because the IRS has indicated that non-submission of reports over several years may be taken as an indication of non-compliance with FATCA.