OECD CRS - Exemption Secured For 'Old And Cold' Cayman CDO/CLO Issuers

The Cayman Islands Tax Information Authority ("TIA") has issued an advisory to confirm that the limited life debt investment entity ("LLDIE") exemption established under FATCA has been extended in the Cayman Islands to the OECD Common Reporting Standard ("CRS").¹ As such, a Cayman Islands LLDIE has been designated as a "Non-Reporting Financial Institution" ("NRFI") and exempt from the due diligence and reporting obligations of CRS as well as FATCA.

The categories of NRFI under CRS are limited and not as broad as those provided under FATCA, which includes additional categories of "Exempt Beneficial Owners" and "Deemed Compliant Financial Institutions" (such as LLDIE), which are all exempt from GIIN registration and reporting under FATCA.