The Cayman Islands is fully committed to the Automatic Exchange of Information (AEOI), implementing both US FATCA and the OECD's Common Reporting Standard (CRS).
The Obligations of Financial Institutions (FIs)
Cayman Investment Funds are classified as Reporting Financial Institutions. This triggers significant compliance burdens:
- Registration: The FI must register with the US IRS to obtain a GIIN (Global Intermediary Identification Number) and register on the Cayman AEOI portal.
- Due Diligence: The FI must collect self-certification forms (W-8, W-9, CRS forms) from all investors to determine their tax residency.
- Reporting: Annually, the FI must report account balances and distributions of reportable persons to the Cayman Tax Information Authority (TIA), which then automatically shares the data with the relevant foreign tax authorities.
Non-Reporting Entities
Certain entities, such as pure holding companies or active non-financial entities (NFFEs), are not considered Financial Institutions. They do not have reporting obligations, but they must still provide self-certifications to their banks or brokers.
| Framework | Target Jurisdiction | Key Identifier |
|---|---|---|
| FATCA | United States | US Citizenship / Residency |
| CRS | 100+ OECD Jurisdictions | Tax Residency Address |