Introduction
Along with its fellow Crown dependencies and overseas territories and other international financial centres, the Cayman Islands now has comprehensive legislation and regulations requiring Cayman-domiciled or registered legal entities which carry on certain activities to have demonstrable substance in the Cayman Islands.
The International Tax Cooperation (Economic Substance) Act reflected the Cayman Islands' commitment to its obligations as a member of the Organisation for Economic Cooperation and Development's global Base Erosion and Profit Shifting Inclusive Framework and corresponding EU requirements for no or nominal tax jurisdictions.
This article summarises the key elements of the International Tax Cooperation (Economic Substance) Act, which has been subject to various updates since its introduction, and draws upon guidance issued by the Tax Information Authority (TIA), which has responsibility for the supervision and implementation of the act.