Bermuda Economic Substance Regulatory Update: Changes To Non-Resident Entity Requirements

There is an exemption from the economic substance requirements for entities that are resident for tax purposes in a jurisdiction outside of Bermuda that is acceptable to the Registrar of Companies (Registrar) provided that (i) all of its income from relevant activities is liable to tax in that jurisdiction; and (ii) that the jurisdiction in which the entity claims to be resident for tax purposes is not on the EU's list of non-cooperative jurisdictions for tax purposes (Exemption). Any entity that wishes to rely on the Exemption is required to make a submission to the Registrar on an annual basis. The Exemption claim must set out the jurisdiction in which the entity claims to be resident for tax purposes and must provide sufficient evidence to support that claim.