Article by Chris Tragheim Deloitte

On 5 November 2013 the Cayman Islands Government became the first Overseas Territory (OT) to sign an agreement on automatic information exchange with the UK. The Agreement is similar to the recently announced UK-Crown Dependency Agreements and is closely aligned with the key timings, requirements and definitions introduced by US FATCA.

Under the Agreement, Financial Institutions in the Cayman Islands will broadly be required to identify and report on UK Persons holding accounts. As with US FATCA and other UK Agreements, the requirements are implemented from 1 July 2014 with some tasks to complete in advance of this date.

However, it should be noted that the first reporting date in respect of UK Persons will be 2016 and, unlike the Crown Dependencies versions, there will be no reciprocal reporting requirement for UK Financial Institutions.

Interestingly, the announcement also confirmed the Cayman Islands’ commitment to developing a multilateral platform for exchange alongside the UK, France, Germany, Italy and Spain. It is understood that parties are working to agree a common global standard for information exchange by 2014 with implementation scheduled for the following year. This is a relatively tight timeline and businesses should continue to monitor development closely.

The text of the Intergovernmental Agreement can be found here. Should you have any questions regarding the agreement, please contact a member of the Deloitte FATCA team, or visit our website at www.deloitte.co.uk/FATCA.

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