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Aki Corsoni-Husain
Aki Corsoni-Husain
  • Aki Corsoni-Husain

  • Partner
  • Cyprus
George Apostolou
George Apostolou
  • George Apostolou

  • Partner
  • Cyprus
Chiara Deceglie
Chiara Deceglie
  • Chiara Deceglie

  • Partner
  • Luxembourg
Massimiliano della Zonca
Massimiliano della Zonca
  • Massimiliano della Zonca

  • Senior Associate
  • Luxembourg
Philip Graham
Philip Graham
  • Philip Graham

  • Partner
  • British Virgin Islands
Ayana Hull
Ayana Hull
  • Ayana Hull

  • Counsel
  • British Virgin Islands
Katerina Katsiami
Katerina Katsiami
  • Katerina Katsiami

  • Associate
  • Cyprus
Petros Kiteos
Petros Kiteos
  • Petros Kiteos

  • Associate
  • Cyprus
Andrew Knight
Andrew Knight
  • Andrew Knight

  • Partner
  • Luxembourg
Joshua Mangeot
Joshua Mangeot
  • Joshua Mangeot

  • Counsel
  • British Virgin Islands
Mirza Manraj
Mirza Manraj
  • Mirza Manraj

  • Counsel
  • Hong Kong
Elina Mantrali
Mirza Manraj
  • Elina Mantrali

  • Associate
  • Cyprus
Vanessa Molloy
Vanessa Molloy
  • Vanessa Molloy

  • Partner
  • Luxembourg
Andrea Moundi Savvides
Andrea Moundi Savvides
  • Andrea Moundi Savvides

  • Consultant
  • Cyprus
Marina Stavrou
Marina Stavrou
  • Marina Stavrou

  • Associate
  • Cyprus
Matt Taber
Matt Taber
  • Matt Taber

  • Partner
  • Cayman Islands
Carolynn Vivian
Carolynn Vivian
  • Carolynn Vivian

  • Senior Associate
  • Cayman Islands

New Cayman Islands Economic Substance Guidance Notes

A new version of the Guidance Notes for Economic Substance for Geographically Mobile Activities (Guidance Notes) was recently published by the Cayman Islands Tax Information Authority (TIA).

The revised Guidance Notes can be found here on the TIA website.

The key change to the Guidance Notes was the inclusion of detailed sector specific guidance for each of the relevant activities. The sector specific guidance sets out the scope of each relevant activity, the types of activities that are likely to be considered a relevant activity and the core income generating activities that are required to be performed for that relevant activity. The Guidance Notes also include several worked examples of typical scenarios for each relevant activity, serving as a helpful reference.

Amendments have also been made to the Guidance Notes to reflect the various legislative changes over the past twelve months, such as:

  • The requirement to provide information to the TIA on the immediate parent, ultimate parent and ultimate beneficial owner of the entity where an entity claims tax residence outside of the Cayman Islands and the requirement for the TIA to then exchange that information with the relevant competent authorities
  • The TIA now having appropriate functions and powers for it to monitor and verify outsourcing of core income generating activities
  • The power for the TIA to now impose a fine where a relevant entity that is required to satisfy the economic substance test fails to prepare and submit to the TIA its annual Economic Substance Report within the specified time (the penalty is CI$5,000 with an additional penalty of CI$500 for each day the breach continues)

Please see our client alert here.