Transfer Pricing in the Cayman Islands: CbCR portal

November 28, 2025

In August 2025, the Cayman Islands Department for International Tax Cooperation (DITC) announced the relaunch of its digital portal for managing Country-by-Country (CbC) reporting obligations. The new system, known as the DITC Portal, re-enables the functions of registration, notification, and filing of country-by-country reports, introducing updated requirements for multinational groups with constituent entities in this jurisdiction.

As part of this update, the DITC has established mandatory re-registration for all multinational groups, regardless of whether they were already registered in the previous system. This measure seeks to strengthen the control, traceability, and consistency of the information submitted under the BEPS Action 13 standard.

Timely compliance with these provisions is essential, as the Cayman Islands are a relevant point in the international structures of many economic groups.

Requirement to re-register on the DITC Portal

The DITC has indicated that all constituent entities of multinational groups domiciled in the Cayman Islands must re-register on the updated portal, even if they had completed this process in previous versions. The deadline for re-registration is November 30, 2025, and only users authorized by the reporting entity may submit notifications or upload the required information. 

This process is essential to maintain the validity of the registration, avoid formal non-compliance, and ensure access to the CbC reporting functions. 

CbC reporting obligations under the Cayman Islands framework 

Scope of reporting 

The Cayman Islands adhere to the international country-by-country reporting standard designed to improve tax transparency and the automatic exchange of information between jurisdictions. The report must include, among other elements: 

  • accumulated income by jurisdiction; 
  • profits or losses before taxes; 
  • taxes paid and accrued; 
  • declared capital; 
  • tangible assets; 
  • number of employees; 
  • list of group entities and general description of their economic activities. 

The information must correspond to the multinational group’s fiscal year, following the technical format required by the DITC, which includes structured electronic files (e.g., XML). 

Deadlines for submission 

The country-by-country report must be submitted within 12 months of the end of the relevant fiscal year. It should be noted that even if the group submits the report in another jurisdiction, this does not exempt the local entity from complying with the reporting and, if applicable, filing obligations in the Cayman Islands. 

Specific features of the CbCR regulatory framework in the Cayman Islands 

No formal requirements for a Master File and Local File 

In the Cayman Islands, there is no requirement to periodically file a Master File or Local File as part of transfer pricing obligations. However, the authority retains the power to request additional information when it deems necessary during review or verification processes.  

This feature reduces the formal documentation burden, although it requires taxpayers to maintain robust and consistent internal records to support the information provided in the country-by-country report. 

Mandatory electronic filing 

The new portal centralizes all processes related to country-by-country reporting, including: 

  • registrations and re-registrations, 
  • reporting entity notifications, 
  • CbC report uploads, 
  • automatic file validations, 
  • access to updated guidelines and formats. 

This scheme seeks to increase administrative efficiency and ensure the quality and integrity of the information transmitted. 

Implications for multinational companies 

The update of the DITC Portal means that multinational groups must carefully review their internal compliance processes. Among the main aspects to consider are: 

  • Verify whether there is any constituent entity located in the Cayman Islands that requires the group to register or re-register. 
  • Determine the entity responsible for filing the report (parent entity or substitute entity). 
  • Prepare in advance the accounting, tax, and operational information required for the country-by-country report. 
  • Review the compatibility of internal information systems with the formats required by the portal. 
  • Implement internal controls to ensure consistency between reported data and financial statements. 

Failure to re-register or meet filing deadlines may result in penalties, restrictions on access to the portal, and potential administrative contingencies.  

Conclusion 

The relaunch of the CbCR portal in the Cayman Islands is a significant step toward modernizing and strengthening its international compliance processes. This new regulatory environment requires multinational groups to review their procedures, maintain up-to-date internal records, and proactively adapt to DITC requirements. 

For companies with a presence in this jurisdiction, having a clear country-by-country reporting policy, a preventive approach, and adequate coordination between tax, financial, and compliance areas will be essential to ensure consistent, timely filing that is aligned with international standards. 

Optimize your CbCR compliance with the support of specialists 

At TPC Group, we have a technical team highly specialized in international obligations, including country-by-country reporting, document management, and the review of intra-group structures in different jurisdictions. We provide comprehensive advice to ensure that your group complies with applicable regulatory standards and minimizes risks with tax authorities. 

Contact us to assess your obligations and strengthen your compliance strategy. 

 

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