Cayman Islands CRS Amendments: Cayman Islands-Based Principal Point of Contact
- Published
- in Industry Updates
Significant amendments to the Common Reporting Standard (“CRS”) have been introduced in the Cayman Islands. Further details of those amendments and implications for Fund managers are available in our legal update, Important Changes to Cayman Islands CRS Framework.
A key operational change to CRS is the new requirement for a Cayman Islands Financial Institution (each an “FI”) to appoint a Principal Point of Contact (“PPoC”) that is resident in the Cayman Islands. Where the PPoC of an FI is not currently resident in the Cayman Islands, the FI is required to appoint a Cayman Islands-based PPoC and notify the Department for International Tax Cooperation (“DITC”) by 31 January 2027.
Maples Group Solutions
The Maples Group’s specialist Regulatory Services team can assist with this new requirement for a Cayman Islands-based PPoC in a number of ways to best suit your circumstances:
PPoC-Only Services
The Maples Group offers the following options for PPoC-only services:
- Event Driven: suitable for FIs currently taking care of FATCA/CRS obligations in house, or who have appointed an external service provider outside the Cayman Islands who they wish to retain for FATCA/CRS services more broadly, and in each case who are now required to appoint a Cayman Islands-based PPoC. This solution provides the minimum required services per FI, including monitoring, review and forwarding of emails and notifications from the DITC, with additional event-driven services provided as required for separate one-time fees.
- Bundled: suitable for clients who may prefer a single annual fee that covers all on-going associated PPoC activities.
For more information on the PPoC-only services, see our PPoC Services overview.
PPoC Entity Solution
Clients that have a large number of FIs may like to consider establishing a Cayman Islands entity to act as PPoC (the “PPoC Entity Solution”)1, rather than having each FI individually appoint a third-party PPoC. A DITC advisory indicated a sponsor-controlled entity registered in the Cayman Islands can act as the PPoC for the sponsor’s FIs under CRS, but any such entity must maintain a physical address in the Cayman Islands (not solely a registered office, mailing and/or correspondence address). 2
The Maples Group can assist with the establishment of a Cayman Islands entity to act as the Cayman Islands-based PPoC to each of your FIs, and can provide office space and a local telephone number to satisfy the “physical address in the Cayman Islands” requirement3.
Full FATCA/CRS Services
The Maples Group provides a FATCA/CRS full service offering that encompasses all aspects of FATCA/CRS compliance (including acting as the Cayman Islands-based PPoC, registration, due diligence and reporting).
Further information, see our FATCA/CRS full-service offering overview.
Timing, Next Steps and Further Information
While DITC Guidance is expected to be released prior the 31 January 2027 deadline, the timing of its release is uncertain and it is not expected to impact the Maples Group solutions. As such we recommend that you start considering your solution options now to avoid any timing issues towards the end of the year (when many other regulatory filings become due).
For further information about these solutions and the associated pricing, please contact your usual Maples Group contact.
1 Individuals/service providers needing access to the DITC portal can be added as additional users, and reporting can continue to be performed by individuals within the client internal tax team or the service provider.
2 We have included office space/local telephone number to satisfy the “physical address in the Cayman Islands” requirement at a minimum, i.e. the “base platform” for the solution. It is possible that DITC guidance may expand the requirements for a physical address beyond those of the base platform, at which stage we can discuss how those additional requirements can be added to the base platform and any associated costs, which may be fact specific and/or client/FI centric. If the DITC guidance does not expand the requirements, the base platform solution will be required in any event.
3 See Footnote 2.
