In a recent Industry Advisory, the Cayman Islands government has announced that they have, in effect, extended the deadline for Cayman Island financial institutions to file a US Foreign Account Tax Compliance Act (FATCA) or Common Reporting Standards (CRS) report to July 31, 2018. While the statutory deadline for Cayman Island financial institutions to file CRS and FATCA reports remains May 31, 2018, the announcement establishes that, so long as 2017 reports are filed on or before July 31, 2018, there will be no adverse consequences, enforcement measures or penalties. The Industry Advisory also gave notice of the government’s intent to shut down the Cayman AEOI Portal from June 1 through June 15, presumably for maintenance.
This new deadline is welcome relief for Cayman financial institutions as many have experienced delays with the Cayman AEOI Portal and some are still delinquent in gathering required information, such as CRS self-certifications. Those seeking to take advantage of the grace period should consider the impact of the portal’s closure before delaying the filing of reports that are otherwise ready. In prior years the maintenance schedule has run long or the portal’s reopening has been met with a flood of users and slow processing time; if the May 31 deadline is missed it will likely be several weeks before reports can be filed. Additionally, there is always a risk that draft data already entered into the system may disappear once the portal reopens. However, with regards to lost data, the Cayman Islands AEOI Portal Team has confirmed to RSM that all items left in draft during the portal’s downtime will, “remain that way until further action is taken.”
While the extension is certainly welcomed relief, RSM recommends that Cayman financial institutions aim to file their required reports by the May 31 deadline if all required information is available and has already been entered into the AEOI Portal.
More information on Cayman Islands FATCA and CRS reporting can be found on the Cayman Islands AEOI news and updates post.
