CbCR Authorisation Letter Template

Summary

This is a fill-in-the-blank template letter published by the Cayman Islands Department for International Tax Cooperation (DITC) for use by multinational enterprise (MNE) groups with Constituent Entities resident in the Cayman Islands. The letter is addressed to the Cayman Islands Tax Information Authority and is used to formally notify the Authority of the individuals appointed as Primary Contact and Secondary Contact for a group's Cayman Islands Constituent Entities under the Country-by-Country Reporting (CbCR) Regulations, 2017.

• Schedule of entities: The Reporting Entity of the MNE Group must list all Cayman Islands Constituent Entities, with their General Registry registration numbers, in a schedule.
• Contact details: The template requires contact details (name, position, email, telephone, business entity, physical address) for both a Primary Contact and a Secondary Contact, who must be two different individuals.
• Primary Contact authority: The Primary Contact is authorised to represent the entities for CbCR compliance purposes and to notify the Authority of changes to required information, other than changes to the Primary Contact's own identity.
• Secondary Contact authority: The Secondary Contact is specifically authorised to notify the Authority of any change to the Primary Contact's identity.
• Signature requirement: The letter must be signed by a Director or Senior Manager.

This is a purely administrative/procedural form rather than a legislative instrument, so it does not itself create new substantive obligations beyond what is already required under the CbCR Regulations. It simply operationalises the notification of contacts required for compliance with those Regulations, including the ongoing obligation to keep the Authority updated if the information changes.

Key obligations

• MNE groups must submit this authorisation letter (or equivalent) to the Cayman Islands Tax Information Authority naming a Primary Contact and Secondary Contact for their Cayman Islands Constituent Entities under the CbCR Regulations
• The Primary and Secondary Contact must be two different individuals
• The letter must list all Cayman Islands Constituent Entities and their Cayman Islands General Registry registration numbers in the schedule
• The Primary Contact is responsible for notifying the Authority of any subsequent change in required information, except changes to the identity of the Primary Contact
• The Secondary Contact is responsible for notifying the Authority of any change in the identity of the Primary Contact
• The Reporting Entity must promptly provide an updated authorisation letter if any information in the letter changes
• The letter must be signed by a Director or Senior Manager of the Reporting Entity

Applies to

MNE Groups, Constituent Entities, Reporting Entities