CbCR Instructions on Constituent Entities File (Updated 25 November 2025)

Summary

This DITC guidance sets out technical instructions for preparing the Constituent Entities File, a CSV file that must be submitted as part of the Country-by-Country Reporting (CbCR) notification process for the Cayman Islands. It applies to the Primary Contact of an MNE Group who is responsible for completing CbCR notifications on the DITC Portal, and covers all Constituent Entities of the MNE Group that are resident in the Cayman Islands, including the Ultimate Parent Entity (UPE) or Surrogate Parent Entity (SPE).

• Required fields: The file must include CbCR Number, CE Name, CE address, CE registration number, CE type, CE's FI Number, and whether the CE is regulated by CIMA.
• Validation rules: Each field must satisfy validation rules for the file to be accepted by the DITC's system, including mandatory completion of all fields and specific formatting requirements (e.g., CR/LC/PX/LP/TR prefixes for registration numbers, FI followed by six digits for FI numbers).
• Sample data: The document provides sample data illustrating correctly formatted entries for companies, partnerships, and trusts (registered and unregistered).

This is a technical/operational guidance document rather than a standalone legal instrument, but compliance with its formatting and validation rules is a practical precondition for a valid CbCR notification submission, since a file that does not conform will be rejected.

Key obligations

• The Primary Contact must complete the CbCR notification process by preparing a single CSV Constituent Entities File, based on the DITC's template, covering all of the MNE Group's Constituent Entities resident in the Cayman Islands (including the UPE or SPE).
• The file must be submitted in CSV format based on the DITC's template; non-conforming format will result in rejection.
• All fields in the Constituent Entities File are mandatory and must not be left blank.
• Required data must be entered exactly as specified (e.g., CbCR Number entered precisely, e.g., CBC00999999).
• Where there is no data for CE registration number and/or CE's FI Number, 'N/A' must be entered in those fields.
• CE registration numbers must be entered in the format used by the General Registry with the applicable prefix for the entity type (CR, LC, PX, LP, TR).
• CE's FI Number, where applicable, must be entered in the format 'FI' followed by six digits.
• The 'Is the CE regulated by CIMA?' field must be answered with only 'Yes' or 'No'.
• CE type must be entered as one of 'Company', 'Partnership', or 'Trust' per the defined categories.

Applies to

Constituent Entities of MNE Groups resident in the Cayman Islands, Reporting Entities/Primary Contacts under CbCR, Companies (including exempted companies, LLCs, Foundation Companies), Partnerships (including general partnerships, exempted limited partnerships, LLPs), Trusts (registered and unregistered, including exempted trusts), Cayman Financial Institutions (CFIs) registered for FATCA/CRS