On 13 June 2019, the Cayman Island’s Department for International Tax Cooperation (DITC) issued an industry advisory informing the following:

1. AEOI Portal, FATCA/CRS reporting deadline: 31 July 2019;

2. Economic substance – update, in particular:

• Legislative assessment – OECD forum on harmful tax practices;
• Economic substance (ES) notification – completion required prior to filing the General Registry’s annual returns; and
• XML schema and systems update.

The development of the DITC’s economic substance portal has commenced and is expected to open mid-2020. A user guide will be published in advance of the portal launch.

All relevant entities are obliged to submit an ES notification through the General Registry system. This procedure is separate from the General Registry’s annual return filings and the mandatory ES notification must be completed and filed electronically, in order to proceed with the necessary filings of the annual returns. The notification must be submitted via a smart form and wherever an entity is claiming for exemption, supporting documents will be required to validate the claim.

The smart form system is expected to be online and further guidance available in Q4 2019.

The industry advisory can be found here.