Annual return deadlines for funds regulated by the Cayman Islands Monetary Authority (CIMA)
15 January 2018 - Annual fees paid to CIMA for registered funds.1
Automatic exchange of information (aka FATCA and CRS) (AEOI)
31 December 2017 - Cayman Islands funds classified as reporting financial institutions (which will effectively be all investment funds including those regulated by CIMA) must have completed their review of Pre-existing Lower Value Individual Accounts and Pre-existing Entity Accounts for CRS2 purposes with reporting next due by 31 May 2018.
Renewal (or cancellation) of registration under the Directors Registration and Licencing Law
31 December 2017 - A director may cancel their registration with CIMA, in order to avoid 2018 fees if:
- the director has resigned or been removed as a director from all covered entities (ie CIMA regulated investment funds and companies registered with CIMA as excluded persons under the Securities Investment Business Law); and/or
- all covered entities of which they are a director have been successfully de-registered from CIMA or placed into "licence under liquidation" status with a voluntary liquidator appointed on or before 31 December 2017.
15 January 2018 - Renewal of registration with CIMA is due for directors of covered entities through the CIMA Director Gateway (https://gateway.cimaconnect.com/).
Liquidation, termination and de-registration of CIMA regulated funds to avoid paying 2018 government fees
19 December 2017 - Board of directors and voting shareholders of the fund must approve placing the fund in voluntary liquidation, appointment of a liquidator and filing of various documents and notices.
20 December 2017 - Details of the proposed liquidation must be filed for publication in the Cayman Islands Gazette.
29 December 2017 - De-registration documents to be filed with CIMA by this date. All filings and fees must also be up-to-date including audited financial accounts and fund annual returns.
If completing the liquidation process after 31 December 2017: board and shareholder resolutions (as applicable), fees and certain forms must be filed with CIMA by 29 December 2017 so that the fund is placed in Licence under Liquidation status. If only the board resolutions and fee are filed, half CIMA fees will be due for 2018 and the fund will be placed in Licence under Termination status by CIMA.
Please see our Guide to Voluntary liquidations for details of the steps to take to liquidate a Cayman Islands company and our client alert on Termination and de-registration fo Cayman regulated funds for more details on the de-registration process with CIMA.
1 Where Harneys Fiduciary provides the registered office of the fund, these fees were included in the fund's annual return invoice that was sent out at the beginning of November and will be paid when payment has been made by the fund to Harneys Fiduciary
2 Cayman Islands legislation implementing the OECD's Common Reporting Standard (CRS)
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