The Economic Substance Guidance Notes were revised on 30 January 2023 and provide that the Registrar will no longer accept an Exemption claim from an entity that is resident for tax purposes in a jurisdiction that does not have a corporate tax regime and/or residency for tax purposes in such jurisdiction does not result in the entity being subject to the equivalent economic substance requirements in that jurisdiction. Some of the jurisdictions which may be rejected by the Registrar in connection with an Exemption application include Anguilla, Bahamas, Bahrain, Barbados, the United Arab Emirates (the Restricted Jurisdictions).

Any Bermuda entity that currently claims an Exemption from a Restricted Jurisdiction should carefully consider its activities and whether it can continue to adhere to the economic substance regime.  Please reach out to your usual Appleby contact or a member of the team below if you have questions regarding the application of the economic substance requirements to your business.

Key contacts

Sally Penrose

Partner, Head of Regulatory: Bermuda

T +1 441 298 3286
E Email Sally

Katie Blundy

Senior Associate: Bermuda

T +1 441 298 3524
E Email Katie

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