Among other things, this will include all corporate collective investment schemes that are structured as “exempt schemes” and that have not appointed an external fund manager.

Affected funds do not have long to prepare: They will be required to comply with the substance rules for all accounting periods commencing after 16 December 2020, so those with a 31 December year-end will have to be substance-compliant by 1 January 2021.

With as little as two weeks to prepare, CSPs and fund administrators should urgently consider whether this change will affect any of their client entities.

Please contact Garry Manley in our Isle of Man office with any questions.

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