As the sole, dedicated channel in the Cayman Islands for international co-operation on matters involving the provision of tax-related information, the Tax Information Authority (TIA) has statutory responsibility in the areas of tax information assistance under the Tax Information Authority Law and reporting of savings income information under the Reporting of Savings Income Information.

Cayman Islands TIA also holds the distinction of having the highest number of financial institutions registered for FATCA and AEOI reporting to them and was among the first group of jurisdictions in the world to become an Early Adopter of the OECD Common Reporting Standard (CRS).

Cayman as a player in the world’s financial architecture needs to meet global standards and comply with global obligations. That’s why the launch of this portal is very important to us. We can safely say that we are ready.

Minister for Financial Services, Wayne Panton

The Challenge

The Cayman Islands entered into Intergovernmental Agreements (IGAs) with the United States and the United Kingdom to improve international tax compliance and to implement FATCA (U.S. Foreign Account Tax Compliance Act). These agreements are in the form of the U.S. Model 1B IGA (non-reciprocal). The Cayman Islands is also committed to the early adoption of the OECD Common Reporting Standard (CRS) for the automatic exchange of financial account information. According to the IRS, almost 30,000 financial institutions registered under FATCA come from the Cayman Islands, making it the country with the highest number of financial institutions registered.

The Cayman Islands required an Automatic Exchange of Information portal that allowed Cayman’s financial institutions to register and report customer data under FATCA in order to comply with international obligations in tax matters, meet commitments to partner jurisdictions, and to demonstrate a commitment to international tax cooperation and adherence to international standards.

In addition, the Cayman Islands TIA required a solution that also complied with OECD standards for AEOI, was able to manage and automate account due diligence requirements as well as identify errors in FATCA and CRS disclosures over and above those identified within the XML schemas, and could ensure the integrity and security of all data.

Timing was also an issue: to meet FATCA requirements, Cayman Islands TIA needed a full functioning solution in time to allow their financial institutions to register before the FATCA deadline.  These systems and processes had to be in place, tested and operational to meet certain legally specified commencement dates in 2015.

In July of 2014 The Government of the Cayman Islands through the Department of International Tax Cooperation sent an Invitation to Tender for the supply and installation of an IT solution for Automatic Reporting of Information for tax purposes.

The Solution

Vizor was selected by the Cayman Islands Tax Information Authority (TIA) to build and implement the Vizor for FATCA & AEOI solution.

Vizor was selected in part due to our out-of-the-box solution which included all of the functionality necessary to meet the commitments associated with US FATCA and AEOI. Our pre-existing partnership with Deloitte, and our successful work to date in the Caribbean with the Central Bank of the Bahamas and the British Virgin Islands International Tax Authority were also factors.

At a high level, the solution requirements were to support the following processes:

  • Enrol with the Cayman Islands Tax Information Authority (TIA) to submit relevant information.
  • Create a filing and upload and submit data via XML file.
  • Complete a manual filing if preferred.
  • Fully automated mode whereas once submitted, an enrolment approval workflow will be initiated, and the system will automatically approve enrolments.
  • View submitted filings.
  • Create/update/deactivate financial institution users.
  • Provide information to FIs regarding the status of their notifications and return submissions.
  • Support management reporting on submissions and FFIs to assist in the day-to-day administration of reporting processes through ad-hoc reports.

The Result

By implementing the Vizor for FATCA & AEOI solution, the Cayman Islands Department for International Tax Cooperation was able to meet their FATCA and AEOI commitments quickly and efficiently with an out of the box solution that was able to launch in March of 2015 timeline – well in advance of the September 30th IRS deadline.

Operational efficiency has been maximized as the solution can operate in a ‘fully automated mode’ requiring minimal manual intervention to exchange information with the IRS and other jurisdictions.