Cayman Islands – Financial Services Update

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Due to the coronavirus (COVID-19) pandemic, the Cayman Islands Registrar of Companies and the Department for International Tax Cooperation (“DITC”) are aware that the financial services industry may be dealing with some disruptions to regular operations. In light of this, the following measures have been taken to ensure that business can continue in these unusual times.

Annual Fees Deferred

As of 26 March 2020, the Cayman Islands Government has deferred the obligation to pay annual fees until 30 June 2020 for corporate entities registered in the Cayman Islands. This fees deferral applies to all companies, including limited liability companies, foundation companies and exempted liability partnerships.

Companies and exempted liability partnerships that fail to pay their annual fees by the 30 June 2020 will be subject to penalties as of 1 July 2020.

Extension for Notification of Certain Changes to the Registrar of Companies

Extensions for 30 days will come into effect for director and officer changes, and for registered offices changes and amended memorandum and articles of association (including increases in share capital). These extensions to file pertain to changes which occurred on or after 1 March 2020. Filings will not incur penalties before 30 April 2020.

Beneficial Ownership Filings

The General Registry is giving a one-month extension for beneficial ownership submissions. The extension goes into effect as of 23 March 2020 and will cease on 20 April 2020.

Annual Return Filing

The annual return filing deadline has been extended until 30 June 2020. The extension will apply to all companies, including limited liability companies, foundation companies and exempted liability partnerships. Penalties for failure to file will come into force on 1 July 2020.

Economic Substance Notification

As a result of the annual return extension for companies, the deadline for Economic Substance Notification (“ESN”) filings is now 30 June 2020. Please note that the ESN submission will remain a prerequisite for companies successfully filing an annual return.

Economic Substance Continuing Obligations

The DITC is conscious that COVID-19 may impact intended travel arrangements during 2020 and therefore the ability of some entities to hold board meetings in the Cayman Islands.  While noting that the ‘directed and managed’ requirement is only one element of the economic substance test (the “ES Test”) contained in The International Tax Co-operation (Economic Substance) Law (2020 Revision) (the “ES Law”), the industry advisory notes that the DITC will consider the fact that board meetings may have been required to be held virtually on a case-by-case basis when determining whether an entity has passed or failed the ES Test. Please note that there are currently no changes to reporting deadlines in respect of the ES Law, with reports for the financial year ended 31 December 2019 due by 31 December 2020.

For details, please visit the below website of Ministry of Financial Services:

If you have any questions regarding the above, please feel free to contact your Sertus Client Services Representative or contact us at

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