The Cayman Islands have issued CRS Guidance Notes
All funds in the Cayman Islands are likely to be required to take two important actions prior to July 2017 in relation to CRS.
They must renew the appointment of the Principal Point of Contact on the new format letter that has been issued by the TIA and each fund even where they have delegated the CRS obligations to their administrator must adopt CRS Polices and Procedures.
1. CRS Policies and Procedures
The CRS Guidance Notes requires that:
“Each Cayman Reporting Financial Institution shall -
(a) establish and maintain written policies and procedures to comply with Part 2 of the CRS Regulations; and
(b) implement and comply with the policies and procedures.”
The Guidance notes can be found HERE. We have prepared a draft CRS manual please contact us if you would like a copy info@mgcayman.com
2. Principal Point of Contact must be renewed
The CRS Guidance Notes require that the Fund directors appoints a Principal Point of Contact (PPoC).
The updated format letter adopted by the TIA can be found HERE.
Dates for the CRS Reporting implementation
The following are the effective dates for the implementation of the CRS in the Cayman
Islands:
31 December 2015;
Pre-existing shareholders to be subjected to due diligence procedures are those in
existence as at 31 December 2015
1 JANUARY 2016
New Accounts requiring self-certification by the shareholders are those opened on or
after 1 January 2016
31 December 2016
The first CRS reporting period ends.
The review of Pre-existing High Value Individual Accounts at 31 December 2015
must be completed.
31 July 2017
The Fund must complete their initial registration (was previously 30 June 2017)
The Fund must complete their reporting to the TIA
by 31 July 2017 for the 2016 reporting year.
31 May 2018 (onwards)
The Fund Institutions must complete their reporting by 31 May of each year after 2017.
30 September 2017
First exchanges of information by the TIA to partner jurisdictions will occur on or
before 30 September 2017
31 December 2017
The review of Pre-existing Lower Value Individual Accounts at 31 December
2015 must be completed by 31 December 2017
The review of Pre-existing Entity Accounts at 31 December 2015 must be
completed by 31 December 2017
Reporting jurisdictions:
COMMON REPORTING STANDARD LIST OF PARTICIPATING JURISDICTIONS
(NOTE: Albania has been removed as a Participating Jurisdiction).
Andorra Ghana Niue
Anguilla Gibraltar Norway
Antigua and Barbuda Greece Panama
Argentina Greenland Poland
Aruba Grenada Portugal
Australia Guernsey Qatar
Austria Hong Kong Romania
Bahamas Hungary Russia
Bahrain Iceland Saint Kitts and Nevis
Barbados India Saint Lucia
Belgium Indonesia Saint Vincent and the Grenadines
Belize Ireland Samoa
Bermuda Isle of Man San Marino
Brazil Israel Saudi Arabia
British Virgin Islands Italy Seychelles
Brunei Darussalam
Japan Singapore
Bulgaria Jersey Sint Maarten
Canada Korea Slovak Republic
Cayman Islands Kuwait Slovenia
Chile Latvia South Africa
China Lebanon Spain
Colombia Liechtenstein Sweden
Cook Islands Lithuania Switzerland
Costa Rica Luxembourg Trinidad and Tobago
Croatia Macau (China) Turkey
Curaçao Malaysia Turks and Caicos Islands
Cyprus Malta United Arab Emirates
Czech Republic Marshall Islands United Kingdom
Denmark Mauritius Uruguay
Dominica Mexico Vanuatu
Estonia Monaco
Faroe Islands Montserrat
Finland Nauru
France Netherlands
Germany New Zealand
(PROVISIONAL LIST
OF REPORTABLE JURISDICTIONS
FOR REPORTS DUE IN 2018 ONWARDS
IN ADDITION TO THE ABOVE)
Andorra Grenada Saint Lucia
Antigua and Barbuda Hong Kong (China) Saint Vincent and the
Grenadines
Aruba Indonesia Samoa
Australia Israel Saudi Arabia
Austria Japan Singapore
Belize Kuwait Sint Maarten
Brazil Lebanon Switzerland
Brunei Darussalam Macau (China) Trinidad and Tobago
Canada Malaysia Turkey
Chile Mauritius Uruguay
China Monaco Vanuatu
Cook Islands New Zealand
Costa Rica Panama
Dominica Russia
Ghana Saint Kitts and Nevis
