AEOI is a collective term encompassing the US Foreign Account Tax Compliance Act ("FATCA"), the UK Crown Dependencies and Overseas Territories Information Exchange ("UK-CDOT"), and the Common Reporting Standard ("CRS"), which impose obligations on financial institutions ("FIs").
Pursuant to the Regulations[1] adopted by the Cayman Islands to implement the AEOI regimes, each Cayman Islands entity that is a FI is required to submit a notification to the Cayman Islands Tax Information Authority (the "TIA") providing specified information. Reporting FIs subject to FATCA are also required to register with the United States Internal Revenue Service (the "IRS") to obtain a Global Intermediary Identification Number (a "GIIN"). All reporting FIs must also implement a due diligence programme to facilitate the identification of any reportable account holders and report on any such accounts to the TIA or provide "nil returns" if no reportable accounts have been identified. The purpose of this guide is to outline the practical steps which a FI should take to facilitate compliance with the above obligations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.