Cayman CRS PPoC: Local Contact Requirements

The Cayman Islands Department for International Tax Cooperation (“DITC”), acting for the Tax Information Authority (“TIA”), has updated the Common Reporting Standard (“CRS”) notification framework for Cayman Financial Institutions (“Fis”). A Cayman Financial Institution, other than an exempted body, must notify the TIA of required information through the DITC Portal, including details of a person in the Islands authorised to act as its principal point of contact (“PPoC”) for CRS compliance purposes.

The Local Nexus Requirement

The statutory formulation is that the PPoC must be a “person, in the Islands”. The DITC has explained that, for a natural person, this means having a physical address in the Cayman Islands. For a legal person, it means being incorporated, registered or established in the Cayman Islands and maintaining a physical address in the Cayman Islands; a mailing or correspondence address alone is not sufficient.