Fund Finance Lawyers & Legal Solutions | Appleby

2026 Key Filing Dates for BVI Companies and Limited Partnerships - Continued Moratorium on Filing Fees

Jeffrey Kirk, Shana Simmonds-Lewis, Maree Martin

Key Developments in the BVI Beneficial Ownership Regime

The BVI Business Companies and Limited Partnerships (Beneficial Ownership) (Amendment) Regulations, 2025 (the “Amendment Regulations”) were gazetted and came into effect on 1 July 2025.  The Amendment Regulations introduced important changes and additions to the BVI Business Companies and Limited Partnerships (Beneficial Ownership) Regulations, 2024 (the “BO Regulations”) including, amongst other changes:   providing additional categories of entities that are exempt from the requirement to file beneficial ownership information with the BVI Registrar of Corporate Affairs (the “Registrar”);   changing the threshold for determination of a “subsidiary” in the relevant exemption from “more than 75%” to “75% or more”; the introduction of provisions for the imposition, effect of and withdrawal of restrictions notices;  the introduction of criteria for legitimate interest access to beneficial ownership information together with a process to apply to the Registrar for an exemption from the disclosure of beneficial ownership information; and  the addition of further penalty provisions in Schedule 3 to the BO Regulations. Transitional provisions: The Amendment Regulations provide that for legal entities incorporated, registered or continued prior to 1 July, 2025, they must be in compliance with the Amendment Regulations within 6 months (by 1 January 2026).  Entities that failed to make their filings by the due date will not be considered to be in good standing.  However, there is a moratorium on filing fees and penalties until 31 March 2026. In addition, applications for inspection of, or a copy of an entry in, a beneficial ownership register (BO Register) will not be accepted before 1 April 2026.  Persons may apply for an exemption from disclosure of beneficial ownership information from 2 January 2026.

Jeffrey Kirk, Shana Simmonds-Lewis, Maree Martin

The New Crypto-Asset Reporting Framework – Relevance for Cayman Investment Funds

The Tax Information Authority (International Tax Compliance) (Crypto-Asset Reporting Framework) Regulations, 2025 (CARF Regulations) came into effect on 1 January 2026 and provide for the collection, reporting and automatic exchange of information on transactions in crypto-assets.  The CARF Regulations will operate in a similar fashion to the existing Cayman Common Reporting Standard (CRS) regime which facilitates the automatic exchange of financial account information.  For information on recent changes to the CRS, please see our December advisory here.

Matt Mulry, Martin Byers, Peter Colegate, Maree Martin

Appleby advises Shenzhen International on issuance of RMB 1 billion 2026 medium term notes

Vincent Chan