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Regulatory Blog

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Cayman widens the net but stops short of imposing public access with new Beneficial Ownership Transparency Bill, 2023
For some years there has been significant focus on whether the Cayman Islands would push through the implementation of a public beneficial ownership register which makes it possible for anyone to find out who is the ultimate beneficial owner of a relevant Cayman entity.
BVI economic substance reporting changes and deadlines
Most companies and limited partnerships registered in the BVI have an economic substance “financial period” of 30 June to 29 June. Reports to the International Tax Authority are due within six months of the financial period end, typically falling around the end of the calendar year.
Cyprus authorities remind entities to submit beneficial owners' data to the register
On 1 September 2023, the Cyprus Department of Registrar of Companies and Intellectual Property issued a notice bringing attention to the mandatory requirement for companies that have been incorporated or registered according to Companies Law Cap. 113, the European public limited liability companies (SE) and the Partnerships as well as their officers/partners, to promptly submit the details and information of their beneficial owners to the Register of Beneficial Owners of Corporate and Other Legal Entities.
CFATF seeks feedback on beneficial ownership methodology revisions
The Caribbean Financial Action Task Force is actively seeking input on its methodology revisions related to Recommendations 24 and 25 concerning beneficial ownership.
Further amendments to the BVI International Tax Authority Act
The British Virgin Islands (BVI) International Tax Authority Act 2018 (as amended, the ITA Act) has been further amended by the International Tax Authority (Amendment) Act 2023, which is effective from 22 March 2023.
British Virgin Islands International Tax Authority publishes updated economic substance rules
On 24 February 2023, the BVI International Tax Authority published version three of its economic substance rules and explanatory notes (the Rules). The Rules primarily impact on BVI entities that engage in certain specified “relevant activities” that require them to demonstrate economic substance in the BVI unless they qualify for exemption due to their tax status.
Additional requirement to access Cyprus’ UBO register
On 3 January 2023, the Cyprus Registrar of Companies announced that, following the suspension of public access to the Beneficial Owner Register in line with the requirements of EU case law, members of staff of obliged entities under the AML regime (eg financial and credit institutions and similar) will need to submit a “solemn declaration” in order to access UBO information on the register moving forward.
Luxembourg adapts access to its Beneficial Owner Register for professionals
In our blog of 8 December we noted that the Luxembourg Ministry of Justice had issued a press release advising that access to Luxembourg’s Beneficial Ownership (BO) register had been restored for a number of professionals, following the European Court of Justice (ECJ) ruling on the BO registers decision, that open public access to the BO registers of EU member state companies is no longer permitted.
Cayman Islands Government issues statement on EU Court of Justice ruling on beneficial ownership registers
The Cayman Islands has had beneficial ownership legislation which requires companies to report on their beneficial ownership to the Registrar of Companies since 2017. Earlier this year the Ministry of Financial Services and Commerce issued a consultation paper regarding an expansion of the regime and to prepare the industry for the possibility of public beneficial ownership registers being introduced during 2023 as requested by the UK.
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