Timeline Archive

Timelines for Implementation in the Cayman Islands, BVI and Ireland

Cayman Islands

2014

1 July 2014

US FATCA/UK FATCA

All financial accounts opened with Reporting Financial Institutions from this date and onwards required to be subject to "new account" due diligence procedures1.  All financial accounts existing as at 30 June 2014 with Reporting Financial Institutions required to be subject to "pre-existing account" due diligence procedures.

1 Note that an election is available under the Cayman US FATCA Regulations to extend the deadline for being a "new entity account" until 31 December 2014.

31 December 2014

US FATCA

Deadline for pre-existing Reporting Financial Institutions to obtain GIINs from the IRS

2015

1 January 2015

US FATCA

Reporting Financial Institutions without GIINs liable to be subject to withholding

30 April 2015

Cayman US FATCA Regulations

Statutory notification deadline for Reporting Financial Institutions.

Comments

This deadline is subject to soft enforcement.  See 29 May 2015 below.

29 May 2015

Cayman US FATCA Regulations

Date upon which the Tax Information Authority is likely to start enforcing the law with respect to notifications.

Comments

The Cayman US FATCA Regulations require notification of: (i) the name of the Reporting Financial Institution; (ii) categorisation of the Reporting Financial Institution (i.e. reporting status); (iii) where registered with the IRS, its GIIN; and (iv) certain details of its principal point of contact.

31 May 2015

Cayman US FATCA Regulations

First statutory reporting deadline (limited reporting) to the Tax Information Authority in respect of US Reportable Accounts.

Comments

This deadline is subject to soft enforcement. See 26 June 2015 below.

26 June 2015

Cayman US FATCA Regulations

Date upon which the Tax Information Authority is likely to start enforcing the law with respect to reporting.

Comments

If there are no US Reportable Accounts identified a nil return can be filed, but this is not mandatory. Failure to file a positive return could result in penalties and/or enforcement action by the Tax Information Authority2.

2 See the Tax Information Authority website for information on the format in which reports are to be submitted.

30 June 2015

Cayman US FATCA Regulations

Pre-existing "high value individual investor" enhanced due diligence to be completed - so called "remediation".

Cayman UK FATCA Regulations

Pre-existing "high value individual investor" enhanced due diligence to be completed - so called "remediation".

16 October 2015

CRS

The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 passed in the Cayman Islands to give effect to CRS from 1 January 2016. 

Comments

Over 90 jurisdictions (including the Cayman Islands) have now committed to adopt CRS in order to start exchanging financial account information.

2016

1 January 2016

CRS

All financial accounts opened with Reporting Financial Institutions from this date and onwards required to be subject to "new account" due diligence procedures.  All financial accounts existing as at 31 December 2015 with Reporting Financial Institutions required to be subject to "pre-existing account" due diligence procedures.

Comments

As with the requirements under the Cayman US FATCA Regulations and the Cayman UK FATCA Regulations, CRS contains detailed requirements for due diligence/information verification/remediation."

30 April 2016

Cayman US FATCA Regulations

Statutory notification deadline for Reporting Financial Institutions who have come into scope since 1 January 2015.

Cayman UK FATCA Regulations

Statutory notification deadline for Reporting Financial Institutions.

Comments

These deadlines are subject to soft enforcement. See 2 September 2016 below.

31 May 2016

Cayman US FATCA Regulations

Second statutory reporting deadline (less limited reporting) to the Tax Information Authority in respect of US Reportable Accounts.

Cayman UK FATCA Regulations

First statutory reporting deadline (limited reporting) to the Tax Information Authority in respect of UK Reportable Accounts.

Comments

These deadlines are subject to soft enforcement.  See 2 September 2016 below.

30 June 2016

Cayman US FATCA Regulations

All other pre-existing investor due diligence to be completed - so called "remediation".

Cayman UK FATCA Regulations

All other pre-existing investor due diligence to be completed - so called "remediation".

2 September 2016

Cayman US FATCA Regulations and Cayman UK FATCA Regulations

Date upon which the Tax Information Authority is likely to start enforcing the law with respect to notifications (see 30 April 2016 above).

Comments

The Cayman US FATCA Regulations and Cayman UK FATCA Regulations require notification of: (i) the name of the Reporting Financial Institution; (ii) categorisation of the Reporting Financial Institution (i.e. reporting status); (iii) where registered with the IRS, its GIIN; and (iv) certain details of its principal point of contact.

Cayman US FATCA Regulations

Date upon which the Tax Information Authority is likely to start enforcing the law with respect to second reporting date deadline in respect of US Reportable Accounts (see 31 May 2016 above).

Cayman UK FATCA Regulations

Date upon which the Tax Information Authority is likely to start enforcing the law with respect to first reporting date deadline in respect of UK Reportable Accounts (see 31 May 2016 above).

Comments

Note that if there are no US or UK Reportable Accounts under FATCA identified a nil return can be filed but this is not mandatory.  Failure to file a positive return could result in penalties and/or enforcement action by the Tax Information Authority.

31 December 2016

CRS

Due diligence on pre-existing "high value" individual account holders to be completed.

2017

30 April 2017

Cayman US FATCA Regulations and UK FATCA Regulations

Statutory notification deadline for Reporting Financial Institutions formed in 2016.

Comments

For US FATCA this deadline is subject to soft enforcement (i.e. 31 July 2017) and is aligned with the CRS registration requirement.

For UK FATCA registration is via the CRS regime (see further below).

CRS

Deadline by which a Cayman Financial Institution is required to register with the Tax Information Authority (the "TIA").

Comments

The CRS deadline for registration is subject to soft enforcement. See 31 July 2017 below.

31 May 2017

Cayman US FATCA Regulations

Third reporting date deadline (full reporting) to the TIA in respect of US Reportable Accounts.

Comments

Under US FATCA, if a Cayman Islands Reporting Financial Institution has no US Reportable Accounts, a nil return can be filed but this is not mandatory. Failure to file a return in respect of Reportable Accounts could result in penalties and/or enforcement action by the TIA.

The TIA has confirmed that for 2017 the reporting deadline is aligned with CRS, i.e. 31 July 2017.

CRS

First reporting date deadline to the TIA in respect of Reportable Accounts under CRS.

Comments

The CRS deadline for reporting is subject to soft enforcement. See 31 July 2017 below.

Cayman UK FATCA Regulations

The TIA has confirmed that Reporting FIs will not have separate registration or reporting obligations regarding UK FATCA this year onwards, as UK reporting will be pursuant to CRS. However, for 2017 reporting, UK FATCA investor classification/reporting rules will be applied, although duplicate reporting is not required for any investor who is a "Specified UK Person" under UK FATCA and also a UK "Reportable Person" under CRS. For 2018 reporting only CRS rules will apply.

30 June 2017

CRS

Date upon which the TIA is likely to start enforcing the law with respect to registration.

Comments

The CRS requires all Cayman Islands Financial Institutions to register through the TIA's portal and to notify it of: (i) the name of the Cayman Financial Institution and any number allocated to it by the TIA; (ii) whether the Cayman Financial Institution is reporting or non-reporting; (iii) its categorisation (i.e. what type of Reporting Financial Institution or what classification of Non-Reporting Financial Institution); and (iv) specified details of the principal point of contact and the individual authorised to advise of changes of its principal point of contact.

31 July 2017

CRS and FATCA

Date upon which the TIA is likely to start enforcing the law with respect to registration.

Comments

The CRS requires all Cayman Islands Financial Institutions to register through the TIA's portal and to notify it of: (i) the name of the Cayman Financial Institution and any number allocated to it by the TIA; (ii) whether the Cayman Financial Institution is reporting or non-reporting; (iii) its categorisation (i.e. what type of Reporting Financial Institution or what classification of Non-Reporting Financial Institution); and (iv) specified details of the principal point of contact and the individual authorised to advise of changes of its principal point of contact.

31 August 2017

CRS and FATCA

Date upon which the TIA is likely to start enforcing the law with respect to reporting.

Comments

Under CRS, in a change to the previous position, a Reporting FI must now file nil returns with the TIA if it has no Reportable Accounts in respect of the previous year. To simplify compliance, it is anticipated that such nil returns will be made using a single check box via the Portal.

Failure to file a return could result in penalties and/or enforcement action by the TIA.

31 December 2017

CRS

Due diligence on pre-existing "lower value" individual account holders and pre-existing entity account holders to be completed.

British Virgin Islands

2016

30 June 2016

BVI US FATCA Regulations

Second statutory deadline (less limited reporting) for reporting to the International Tax Authority in respect of US Reportable Accounts for the reporting year 2015.

BVI UK FATCA Regulations

Extended statutory enrolment deadline for Reporting Financial Institutions.

Comments

The BVI US FATCA Regulations and BVI UK FATCA Regulations require enrolment of: (i) the name of the Reporting Financial Institution; (ii) categorisation of the Reporting Financial Institution (i.e. reporting status); and (iii) where registered with the IRS, its GIIN; and (iv) certain details of the Primary User of the BVIFARS portal.

Note that where no Reportable Accounts are identified under US FATCA or UK FATCA, then the Reporting Financial Institution does not need to enroll on the BVIFARS portal and does not need to make any returns.  If the Reporting Financial Institution chooses to enrol or has already enrolled on the BVIFARS portal but has no Reportable Account for the relevant period, no return needs to be submitted for such period.

29 July 2016

BVI UK FATCA Regulations

First (extended) statutory deadline for reporting to the International Tax Authority in respect of UK Reportable Accounts for the reporting period 1 July 2014 and 31 December 2015.

30 September 2016

BVI UK FATCA

Deadline for e-mailing the International Tax Authority with the filing under the Alternative Reporting Regime (ARR) for those who had elected to use the ARR prior to 30 September 2015.

31 December 2016

CRS

Due diligence on pre-existing "high value" individual account holders to be completed.

2017

30 April 2017

CRS

Deadline by which a Reporting Financial Institution is required to make certain notifications as to its CRS reporting status to the International Tax Authority.

Comments

This deadline is subject to soft enforcement. See 30 June below.
The CRS requires enrolment of: (i) the name of the Reporting Financial Institution; (ii) categorisation of the Reporting Financial Institutions (i.e. reporting status); and (iii) certain details of its Primary User of the BVIFARS portal.

31 May 2017

BVI US FATCA Regulations

Third statutory deadline (full reporting) for reporting to the International Tax Authority in respect of US Reportable Accounts for the reporting period 2016.

Comments

Note that if there are i) no US or UK Reportable Accounts under FATCA and/or ii) no Reportable Accounts under CRS identified, the Reporting Financial Institution is not required to enrol on the BVIFARS portal.  In the event that is has already enrolled, a nil return can be filed but this is not mandatory. Failure to file a positive return could result in penalties and/or enforcement action by the International Tax Authority.

As the UK is also a Reportable Jurisdiction under CRS, there is currently a requirement to report under both the BVI UK FATCA Regulations and CRS.

30 June 2017

CRS

Deadline for enrolment on BVIFARS portal for CRS where not already enrolled for US FATCA or UK FATCA.

31 July 2017

BVI UK FATCA Regulations

Second statutory deadline (full reporting) for reporting to the International Tax Authority in respect of UK Reportable Accounts for the reporting period 2016.

CRS

First statutory deadline for reporting to the International Tax Authority in respect of relevant Reportable Accounts under CRS for the reporting period 2016.

31 December 2017

CRS

Due diligence on pre-existing "lower value" individual account holders and pre-existing entity account holders to be completed.

Ireland

2016

30 June 2016

Ireland US FATCA Regulations

  1. FATCA reporting date deadline to the Irish Revenue Commissioners for Irish Financial Institutions in respect of US Reportable Accounts or nil returns for the 2015 year.
  2. Review of low value pre-existing individual accounts and review of pre-existing entity accounts where the account balance or value of that account exceeds $250,000 on 30 June 2014 to be completed by this date.

31 December 2016

CRS

Due diligence on pre-existing "high value" individual account holders to be completed.

2017

30 June 2017

Ireland US FATCA Regulations

  1. FATCA reporting date deadline to the Irish Revenue Commissioners for Irish Financial Institutions in respect of US Reportable Accounts or nil returns for the 2016 year.
  2. First CRS reporting date deadline to the Irish Revenue Commissioners for Irish Financial Institutions for the 2016 year.

31 December 2017

CRS

Due diligence on pre-existing "lower value" individual account holders and pre-existing entity account holders to be completed.