Cayman Islands economic substance requirements – an overview

This briefing summarises the key elements of the The International Tax Co-operation (Economic Substance) Act, which has been subject to various updates since its introduction, and draws upon guidance issued by the Cayman Islands Tax Information Authority.

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Will 2021 be the year of special purpose acquisition companies (SPACs) in Luxembourg?

While SPACs have existed for decades on public markets, a revival seems to be taking place, with SPACs representing about 60 percent of IPOs in the US in 2020. February 2021 saw the launch of the first Luxembourg SPAC in more than 10 years, highlighting the potential for Luxembourg to become the European hub for this type of funding structure. The jurisdiction not only offers a flexible and tax efficient legal framework but also the ability to rely on the European passport mechanism set forth in the Prospectus Regulation.

Using provisional liquidation offshore to preserve bondholder claims under keepwell deeds

Offshore companies are frequently used to facilitate debt finance transactions for large PRC based corporate groups. In the context of a bond issue, the corporate group will often incorporate an offshore subsidiary for the sole purpose of acting as the bond issuer. Bondholders, naturally, expect some form of credit protection, which the offshore subsidiary cannot […]

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‘Tax Day’ – government continues its campaign to tackle non-compliance

In the UK’s first ever ‘Tax Day’ on 23 March 2021, the government released more than 30 consultation documents relating to the future landscape of the UK tax regime. Whilst these documents scrutinised how taxes should be paid, opportunities for simplification and the potential of digitalisation, it was tackling non-compliance which was firmly in the spotlight once again. Tax & estate planning Partner, James Austen, gives his opinion on the proposed measures.

Fraud in the sub line market – should we be concerned?

In recent weeks, news of the JES Global Capital fraud committed by fund manager Elliot Smerling has come to light. Unfortunately, we live in world where fraud, much like death and taxes, is inevitable.

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