DITC FAQs (CRS, FATCA, CbCR, CARF)

Summary

This document is the DITC's (Department for International Tax Cooperation) online FAQ page covering general queries as well as specific guidance on CRS, FATCA, Country-by-Country Reporting (CbCR) and related portal processes. It clarifies procedural questions such as how to register, notify, and report through the DITC Portal, and provides interpretive guidance on completing the CRS Compliance Form and CbC Reports/Notifications.

The FAQs apply to Cayman Islands Financial Institutions (FIs) subject to CRS and FATCA reporting, Trustee Documented Trusts (TDTs), and Reporting Entities (Ultimate Parent Entities or Surrogate Parent Entities) of Multinational Enterprise (MNE) Groups subject to CbCR. It explains one-off Notification requirements, annual CRS Compliance Form obligations, CbCR Notification and Reporting deadlines, and gives detailed technical guidance on how to treat joint accounts, non-reportable accounts, audited financial statements, and currency reporting in the CRS Compliance Form.

• CRS Compliance Form deadline: Annual deadline of 15 September; missing it results in an automatic administrative penalty.
• CbCR deadlines: CbCR Notification and Reporting deadlines are tied to fiscal year end.
• One-time extension: Certain MNE Groups' 2024 fiscal year CbC Report filings with an original deadline between 31 July 2025 and 31 December 2025 have been extended to 27 February 2026.

Key obligations

• FIs must include the TIN and date of birth for all individual Reportable Persons (Account Holders and Controlling Persons) in the CRS Return if the FI holds that information; the XML submission will not validate if these fields are present but empty.
• New FIs must submit a one-off Notification via the DITC Portal to register before submitting Reporting.
• All FIs with CRS reporting obligations, including Trustee Documented Trusts (TDTs), must complete and submit the CRS Compliance Form annually via the DITC Portal by 15 September.
• Failure to submit the CRS Compliance Form by the 15 September deadline puts the FI in breach of Part 2 of the CRS Regulations and results in an automatic administrative penalty.
• Only the Principal Point of Contact (PPoC) or an assigned Secondary User may submit the CRS Compliance Form.
• A Reporting Entity (UPE or SPE) resident in the Cayman Islands must submit a CbC Report for its MNE Group via the DITC Portal within 12 months of the end of the relevant fiscal year.
• A CbCR Notification (or update to an existing Notification) must be submitted before the end of the relevant fiscal year; this is otherwise a one-off process unless details change.
• MNE Groups with a CbCR filing deadline between 31 July 2025 and 31 December 2025 must file their 2024 fiscal year CbC Report by the extended deadline of 27 February 2026.

Applies to

Financial Institutions (FIs), Trustee Documented Trusts (TDTs), Reporting Entities (Ultimate Parent Entities / Surrogate Parent Entities), Multinational Enterprise (MNE) Groups, Constituent Entities

Deadlines

• 15 September: Annual deadline for FIs (including TDTs) to submit the CRS Compliance Form via the DITC Portal.
• within 12 months of the end of the relevant Fiscal Year: Standard deadline for a Reporting Entity to submit its CbC Report for an MNE Group.
• before the end of the relevant Fiscal Year: Deadline for submitting or updating a CbCR Notification.
• 27 February 2026: Extended CbC Report filing deadline for 2024 fiscal year filings only, for MNE Groups whose original filing deadline fell between 31 July 2025 and 31 December 2025, per the 3 December 2025 Industry Advisory extension notice.