CbCR Guidelines (Version 1.3, 18 August 2025)

Summary

This document is DITC guidance (Version 1.3, dated 18 August 2025) explaining how Country-by-Country Reporting (CbCR) works in the Cayman Islands under the Tax Information Authority (International Tax Compliance (Country-by-Country Reporting) Regulations, 2017. It replaces earlier CbCR Guidance Notes (v1.1 and its amendment) and is intended to help multinational enterprise (MNE) groups and their Cayman-resident entities understand their notification and reporting obligations, though it does not itself expand or restrict the scope of the underlying Regulations.

CbCR applies to MNE Groups with annual consolidated group revenue of at least US$850 million (or €750 million equivalent) in the preceding Fiscal Year.

• Notification obligation: Constituent Entities resident in the Cayman Islands (whether incorporated/established there, having a place of effective management there, or subject to financial supervision there) have a notification obligation, which must be performed centrally by the Reporting Entity (normally the Ultimate Parent Entity, or in some cases a Surrogate Parent Entity) of the MNE Group.
• Reporting obligation: Reporting Entities resident in the Islands must file a CbC Report with the DITC (acting for the Tax Information Authority), which will then exchange the report with partner jurisdictions under Qualifying Competent Authority Agreements via the OECD's Common Transmission System (or IRS IDES for the US).
• Master files and local files: These are not required as part of the normal Cayman CbCR reporting cycle, though the Authority may request equivalent information separately.
• Filing channel: All notifications and reports must be submitted through the DITC Portal per the DITC Portal User Guide.
• Duplicate filings elsewhere: A Reporting Entity must still comply with its Cayman filing obligation even if a CbC Report has been or will be filed for the same MNE Group in another jurisdiction.

Key obligations

• Every entity resident in the Cayman Islands must determine whether it is a Constituent Entity of an MNE Group for CbCR purposes and identify the Reporting Entity of that MNE Group.
• Constituent Entities resident in the Islands must ensure a single, centralised notification is made to the Authority for all Constituent Entities in the same MNE Group resident in the Islands.
• The Reporting Entity must make (or update) the notification before the end of the relevant Fiscal Year.
• The Reporting Entity of an MNE Group with Constituent Entities resident in the Islands must appoint a Primary Contact and a Secondary Contact as specified in the DITC Portal User Guide.
• Any Reporting Entity (UPE or SPE) resident in the Islands must file a Country-by-Country Report (CbC Report) with the Authority within 12 months of the end of the relevant Fiscal Year.
• A Reporting Entity must comply with its Cayman Islands CbC reporting obligation even if it has filed, or is required to file, a similar report in another jurisdiction.
• Constituent Entities and Reporting Entities must fulfil their notification and reporting obligations via the DITC Portal in accordance with the DITC Portal User Guide.
• Reporting Entities must adopt a reasonable, practical and consistent approach when completing CbC Reports, following DITC Portal User Guide validation rules in addition to OECD Final Report requirements.

Applies to

MNE Groups, Reporting Entities (Ultimate Parent Entities), Surrogate Parent Entities, Constituent Entities resident in the Cayman Islands

Deadlines

• before the end of the relevant Fiscal Year: Deadline for first notification, or update to an existing notification, in respect of any subsequent Fiscal Year.
• within 12 months of the end of the relevant Fiscal Year: Deadline for Reporting Entities resident in the Islands to file the CbC Report with the Authority.