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ARTICLE · 13 MARCH 2019

Cayman Islands Economic Substance Requirements For Certain Entities - Overview

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On 27 December 2018, the Cayman Islands published The International Tax Co-operation (Economic Substance) Law, 20181 and The International Tax Co-operation (Economic Substance) (Prescribed Date)

Cayman IslandsFinance and Banking

On 27 December 2018, the Cayman Islands published The International Tax Co-operation (Economic Substance) Law, 20181 and The International Tax Co-operation (Economic Substance) (Prescribed Date) Regulations, 2018 (together, the "Initial Law").

The Initial Law was amended on 22 February 2019 by the publication of The International Tax Co-operation (Economic Substance) (Amendment of Schedule) Regulations, 20192 (the "Regulations" and, together with the Initial Law, the "Economic Substance Law") and supplemented by the issuance of the first version of the related Guidance on Economic Substance for Geographically Mobile Activities3 (the "Guidance").

The Economic Substance Law is responsive to global OECD Base Erosion and Profit Shifting ("BEPS") standards regarding geographically mobile activities. Requirements of this type are rapidly being implemented on a level playing field basis by all OECD-compliant 'no or only nominal tax' jurisdictions.

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