Economic substance in the Cayman Islands

The International Tax Co-operation (Economic Substance) Law (2020 Revision) (as amended, the Substance Law) imposes economic substance requirements on companies and LLCs in the Cayman Islands. The Substance Law was introduced in response to concerns of the EU Code of Conduct Group regarding favourable tax regimes facilitating offshore structures that generate profits without real economic activity. The Substance Law also reflects Cayman's commitment as a member of the OECD's Inclusive Framework on Base Erosion and Profit Shifting (BEPS) and, in particular, BEPS Action 5.