On 5 July 2023, the Cayman Island’s Department for International Tax Cooperation (DITC) reminded the industry of important information regarding CRS reporting.

Please take note of the following:

Submission deadline

All Financial Institutions (FIs) with a CRS reporting obligation must submit their 2022 CRS filing declaration to the Tax Information Authority no later than 31 July 2023.

The CRS requires the inclusion of the date of birth for all individuals in the XML report. Some exclusions apply. Please refer to the DITC's Explanatory Note for further details, here.

Additionally, the CRS mandates the reporting of Taxpayer Identification Numbers (TIN) for all persons in the XML report. Certain exclusions are allowed. Please consult the DITC's Explanatory Note for more information, here.

Revised IRS TIN placeholder codes

In January 2023, the IRS issued notice 2023-11, here, which introduces Foreign Financial Institution Temporary US Taxpayer Identification Number Relief. Specifically, please note the following:

The updated list of acceptable placeholder TINs can be found in Question 6 of the IRS Reporting FAQs, here.

The DITC Portal User Guide has been updated (see pages 57-59) for guidance on how the TIN placeholder codes should be used and can be found here.

2022 CRS & FATCA Reporting Deadlines

• CRS Reporting: 31 July 2023
• CRS Filing Declaration (nil return): 31 July 2023
• FATCA Reporting: 31 July 2023
• CRS Compliance Form: 15 September 2023

For more details on these requirements, please refer to the Updates Bulletin issued by DITC, here.