On September 15, 2021, Cayman filers will have to submit the new CRS Compliance Form, which will be due annually on that date. The CRS Compliance Form is required for the first time this year under the new CRS (Amendment) Regulations that entered into force on April 16, 2020. These Regulations amended Reg. 9 to require the Financial Institutions provide additional information annually to the Authority. The CRS Compliance Form is required this year for both 2019 and 2020 tax years and for all Entities that terminated after 16 April 2020.
Filers will complete the Compliance Form using the online smart form on the Cayman DITC Portal or in a bulk CSV upload. The bulk upload form is an alternative to the smartform version and is meant for filers with access to a large number of Financial Institutions on the Cayman Portal. The CRS Compliance Form must be completed annually by all Reporting Financial Institutions for the same reporting period as their CRS returns. There is one exception for Financial Institutions that have indicated they are investment managers or advisors that have No Financial Accounts under the regulations (see Section VII.C.1.a of Schedule 1).
As of August 18, 2021, the function to submit the CSV file to the Portal is not available, so be sure to check regularly with the Portal for updates on its functionality.
See page 30 of the Cayman CRS Guidelines for details on what the Compliance Form must include here: https://www.ditc.ky/wp-content/uploads/ditc_crs_guidelines.pdf
See page 3 of the Cayman Updates Bulletin for details on how to bulk upload the CSV template for the CRS Compliance Form here: https://www.ditc.ky/wp-content/uploads/news-updates.pdf