In our alert “ FATCA Notification and Reporting – Are you ready?” we reported that Cayman Islands Financial Institutions (“Cayman Islands FIs”) must notify the Cayman Islands Tax Information Authority, Department for International Tax Cooperation (“TIA”) on or before 30 April 2015 and report on U.S. Reportable Accounts on or before 31 May 2015.

WHAT’S NEW?

Cayman Islands FIs should be aware of the following new information:

(i) the Cayman Automatic Exchange of Information Portal (AEOI Portal) is now OPEN;

(ii) the TIA has issued an AEOI Portal User Guide which includes helpful information on how to notify and report; and

(iii) Cayman Islands FIs who do not have any Reportable Accounts are no longer required to mandatory report to the TIA on a NIL report basis, but the requirement to notify the TIA by 30 April 2015 still applies.

AEOI Portal Now OPEN

The TIA has launched the AEOI Portal which can be accessed through its website: http://www.tia.gov.ky/html/contact.htm#.

Notifications (i.e. registrations) and reporting may be conducted by or on behalf of Cayman Islands FIs directly to the TIA via the AEOI Portal.

AEOI Portal User Guide

The TIA has published a User Guide for the AEOI Portal in order to assist Cayman Islands FIs making filings. The User Guide can be accessed through the following link here.

Cayman Islands FIs are required to complete a notification form on the AEOI Portal. When completing the AEOI notification form, the Cayman Islands FI is required to upload a pdf letter on letterhead (if possible) identifying and providing authorisation for a third party provider or individual to be assigned as the principal point of contact on behalf of that Cayman Islands FI. The letter should include at a minimum: the Cayman Islands FI name, GIIN, full name and business contact details of the person providing the authorisation, along with the full name and office address of the principal point of contact.

NIL Return Reporting Non-Mandatory

Cayman Islands FIs who do not have any Reportable Accounts are no longer required to mandatory report to the TIA on a NIL report basis. This means that only Cayman Islands FIs with U.S. Reportable Accounts will be required to report to the TIA on or before 31 May 2015.

However, please note that Cayman Islands FIs with no U.S. Reportable Accounts are still required to complete the notification form on the AEOI Portal by 30 April 2015.

Further Guidance

For further guidance on FATCA please contact us.