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FATCA, UK CDOT and CRS Important Updates

April 2016 Gene A. DaCosta


2016 Notification and Reporting Deadlines for FATCA and UK CDOT Extended

The Cayman Islands Government has confirmed for both US FATCA and UK CDOT, notifications may be submitted on or before 10 June 2016 (previously the deadline was 30 April 2016) and returns must be reported on or before Friday 8 July 2016 (previously the deadline was 31 May 2016). No adverse consequences or enforcement measures will be attracted provided that compliance is undertaken on or before these dates. The soft approach to enforcement is in recognition of the first year of compliance for UK CDOT and due to the fact that the AEOI Portal for notifications and reporting is not yet operational for UK CDOT reporting.

For a summary of key reporting dates in 2016 please see here.


Guidance Notes Issued

On 12 April 2016, following industry consultation, the Department for International Tax Cooperation (the “DITC”), issued the Cayman Islands Common Reporting Standard Guidance Notes. A copy of the Guidance Notes can be accessed here.

New Entity Self Certification

Under CRS, it is necessary to carry out self-certification on new accounts from 1 January 2016. The DITC has issued comprehensive individual and entity self-certification forms. On 12 April 2016 the DITC issued an updated entity self-certification form here.

Participating Jurisdictions

An updated list of Participating Jurisdictions has been issued and can be accessed here.

For further information on FATCA, UK CDOT or CRS please contact our attorneys or corporate services professionals in the Cayman Islands office. Earlier publications can be accessed at Impact of FATCA on Cayman Entities and CRS.


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FATCA, UK CDOT and CRS Important Updates


Gene A. DaCosta

Cayman Islands   +1 345 814 7765


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