Latest CDOT & CRS Updates

April 15, 2016

This week there is so much going on in the world of global information reporting that our expert compliance and research team has compiled a separate list devoted to CDOT and CRS updates.

Australia, Guernsey, Jersey, Mauritius, and Norway Release CRS Guidance

This week the countries of Australia, Guernsey, Jersey, Mauritius, and Norway released guidance for the Common Reporting Standard. Australia, Jersey, and Norway had not previously released any guidance, whereas, last year, Guernsey and Mauritius had each released a publication.

Australia and Mauritius are late adopters. They have established their first reporting due date is July 31, 2018.  Guernsey and Jersey are early adopters, who have their first due date on June 30, 2017.  Finally, Norway is an early adopter with a due date of February 1, 2017.

All five countries have signed the Multilateral Competent Authority Agreement. Please click the below links to read each country’s competency agreement:


UK Releases New Schema Guidance

UK has recently released a new schema guidance for its AEOI (CRS) returns. The new version, 1.5., replaces 1.4., which was released May 2015. The new release does not affect the way that Reporting United Kingdom Financial Institutions will make their FATCA and CDOT returns in May.

The guidance is located within a zip file.


BVI Announces CDOT Portal Opening and Extends CDOT Due Date

The British Virgin Islands has recently announced that its portal, BVIFARS, will be ready to accept UK CDOT filings on May 2. The deadline to report as extended its due date for CDOT reporting.  The new date has been moved from May 31 to July 29. Moreover, the deadline to register with the International Tax Authority has been moved from April 1 to June 10.

Please note, the new deadline does not extend the due date for reporting under the Alternative Reporting Regime, or ARR.

Finally, reporting under US FATCA remains the same.


Turks and Caicos Revises International Tax Compliance Regulations & Provides FATCA and CRS Filing Due Dates

There a few changes from a previous revision with the most prominent changes being the new due dates for FATCA and CRS Returns:

  • FATCA and CRS reporting due dates have been changed from their original May 31st date:
    • 2015 FATCA returns are to be submitted electronically by June 30th
    • 2016 CRS returns are due by March 31st
    • The CDOT due date remains the same: May 31st
  • The definition for “pre-existing account” has been added, the definition for a “pre-existing entity account” has been changed, and the definition of a “related entity” has been added as well
  • Changes have been made to the “Modification of due diligence requirements: the CRS” section
  • Language was added explicitly allowing Reporting Financial Institutions to use service providers for both due diligence and reporting obligations


Cayman Islands Extends CDOT Reporting Date, Releases New Portal User Guide & Announces CDOT Filing

The Ministry of Financial Services has recently announced that it will extend the due date for UK CDOT reporting to July 8.  The previous deadline was May 31.  Moreover, the deadline to register is now June 10.

The Cayman Islands Department of International Tax Cooperation has released a new Portal User Guide, version 1.3.   The purpose of the Guide is to provide an instructional “how-to” guide to some of the more commonly used functionalities with the portal. For the new version, the new guidance has information, in chapter 6, which details how FIs are to properly respond to IRS notifications.  The new guidance also has information in chapter 7 that details how to create a corrected return.


The Department has also advised that UK CDOT submission will be available in May 2016 since the AEOI Portal is still being developed.  This announcement came in the AEOI News & Updates, which can be found at the link below.


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