On 15 December 2017 the Tax Information Authority (International Tax Compliance) (Country-by-Country Reporting) Regulations, 2017 (CbCR Regulations) were made and gazetted by the Cayman Islands Ministry of Financial Services and Home Affairs. For those affected by the CbCR Regulations, there may be reporting obligations by as early as 31 March 2018. Given the short time frame, any funds that are impacted should begin making preparations immediately.
While it is expected that many funds will not have a reporting requirement, it is not always immediately apparent whether or not this is the case. Therefore, given the potential sensitivity of the additional disclosures involved, the potential for penalties for non-compliance, and potential interest of this issue that may come from investors / limited partners (LPs), we strongly advise funds to prepare an analysis of the impact of these new regulations to confirm whether or not they need to comply.
Transfer Pricing Director
Tel: + 2289 3508