Introduction

On March 3 2017 the Department for International Tax Cooperation (DITC) announced that the 2017 deadlines for notification and reporting obligations under the Common Reporting Standard (CRS) regulations will be extended by two months. Cayman financial institutions (as defined in the regulations – for more information please see "Amended CRS regulations adopted") will now have until June 30 2017 to register with the Tax Information Authority (TIA) on the Cayman Automatic Exchange of Information (AEOI) online portal without the TIA considering compliance measures or penalties. Reporting obligations for Cayman reporting financial institutions (as defined in the regulations) for accounts opened since January 1 2016 must now be complied with by July 31 2017, with the reports submitted and showing the status 'accepted' on the AEOI portal by that date.

The TIA is consulting industry on proposed revised CRS guidance notes and planning to issue a revised AEOI portal user guide in due course.

Notification and reporting obligations

The DITC also confirmed that Cayman reporting financial institutions will not have notification or reporting obligations under the UK Crown Dependency and Overseas Territories International Tax Compliance Regulations (UK CDOT) from 2017 onwards, as those obligations are superseded by the obligations under the CRS regulations. Any reporting which those institutions would have done under UK CDOT will now have to be done in compliance with the regulations. However, notification and reporting obligations under the Cayman implementation of the US Foreign Account Tax Compliance Act (and 2014 and 2015 reporting obligations under UK CDOT) remain unchanged.

For further information on this topic please contact Jonathan Culshaw at Harneys' Hong Kong office by telephone (+852 3195 7200) or email (jonathan.culshaw@harneys.com). Alternatively, contact Sean Scott at Harneys' Cayman office by telephone (+44 20 7842 6080) or email (sean.scott@harneys.com). The Harneys website can be accessed at www.harneys.com.

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