Economic Substance Requirements

1. INTRODUCTION

The International Tax Co-operation (Economic Substance) Act (2021 Revision) (the "ES Act") came into force on 1 January 2019. The ES Act requires that all Cayman Islands entities notify the Cayman Islands Tax Information Authority (the "TIA") of, amongst other things, whether or not they are carrying on a "Relevant Activity" (as defined in the ES Act and as discussed further below) and, if so, whether or not they are a "Relevant Entity" (see further below). The notification to the TIA is by way of an annual Economic Substance Notification ("ESN") which must be filed prior to an entity filing its annual return with the General Registry's Corporate Administration Portal ("CAP").