{"kind":"expression","expression":{"expr_id":"2200","doc_id":"2200","label":"International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019","is_as_enacted":"f","commenced_on":null,"superseded_on":null,"valid_from":null,"valid_to":null,"is_current":"t","incorporating":null,"akn_expr_iri":"\/akn\/ky\/bill\/2019\/29\/eng@2019-01-01","akn_envelope":"{\"_canary\": {\"iri\": {\"work\": \"\/akn\/ky\/bill\/2019\/29\", \"expression\": \"\/akn\/ky\/bill\/2019\/29\/eng@2019-01-01\", \"manifestation\": \"\/akn\/ky\/bill\/2019\/29\/eng@2019-01-01.pdf\"}, \"pdf\": {\"md5\": \"318aa7ed54eb4c76c69dc3e896133055\", \"path\": \"\/Users\/q\/kyleg-data\/working\/BILLS\/2019\/2019-0029\/2019-0029.pdf\", \"pages\": 12, \"filename\": \"2019-0029.pdf\"}, \"errors\": [], \"extraction\": {\"model\": null, \"stats\": {\"word_count\": 2325, \"paragraph_count\": 8, \"text_char_count\": 14991}, \"usage\": null, \"method\": \"pymupdf-text\", \"version\": \"kyleg-akn-1.0\", \"extracted_at\": \"2026-07-18\"}, \"classification\": \"text_layer\", \"validation_flags\": [], \"docai_processor_id\": null}, \"akomaNtoso\": {\"act\": null, \"doc\": null, \"bill\": {\"body\": [{\"eId\": \"sec_n1\", \"num\": null, \"text\": \"INTERNATIONAL TAX CO-OPERATION (ECONOMIC SUBSTANCE) (AMENDMENT) BILL, 2019 A BILL FOR A LAW TO AMEND THE INTERNATIONAL TAX CO-OPERATION (ECONOMIC SUBSTANCE) LAW, 2018 TO MAKE CHANGES TO THE ECONOMIC SUBSTANCE NOTIFICATION REQUIREMENTS AND THE REQUIREMENTS TO PROVIDE AND SHARE INFORMATION; AND FOR INCIDENTAL AND CONNECTED PURPOSES Introduced PUBLISHING DETAILS Sponsoring Ministry\/Portfolio: Ministry of Financial Services and Home Affairs (FSHA) International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Objects and Reasons Introduced Memorandum of OBJECTS AND REASONS This Bill seeks to amend the International Tax Co-operation (Economic Substance) Law, 2018, (the \u201cprincipal Law\u201d) to make changes to the economic substance notification requirements and the provision and sharing of information. Clause 1 provides the short title of the legislation. Clause 2 amends section 4 of the principal Law to delete the words \u201cCayman Islands\u201d where they appear in that section in relation to core income generating activity. Clause 3 amends section 5 of the principal Law to remove the requirement for the Tax Information Authority (the \u201cAuthority\u201d) to seek the approval of the Cabinet before issuing guidance. Clause 4 amends section 7 of the principal Law by changing the notification requirements so that an entity rather than a relevant entity is required to notify the Authority annually of, among other things, whether or not it is carrying on a relevant activity and if it is carrying on a relevant activity, whether or not it is a relevant entity. In the case of an entity that is tax resident in a jurisdiction outside the Islands, the nameand address of its immediate parent, ultimate parent and ultimate beneficial owner of the entity. The jurisdiction in which the entity is claiming to be tax resident and the supporting information is also required. The amendment also provides for the verification of any outsourcing of core income generating activities. A definition for the term \u201centity\u201d is provided so that in section 7 of the principal Law the reference is to entities incorporated or registered in the Cayman Islands. Clause 4 also amends section 7 of the principal Law to give the Authority the power to impose a penalty for failure to comply with the requirement to provide a report under section 7 of the principal Law. Clause 5 amends section 10 of the principal Law to substitute references to the terms \u201cparent company\u201d and \u201cultimate parent company\u201d with references to the terms \u201cimmediate parent\u201d and ultimate parent\u201d. Clause 5 also adds a new subsection to section 10. The new subsection imposes an obligation on the Authority, in the case of an entity that is tax resident in a jurisdiction outside of the Islands, in accordance with relevant international standards and scheduled agreements, to provide the information provided to it to the competent authority in \u2014 (a) the jurisdiction in which that entity is tax resident; (b) the jurisdiction in which the immediate parent, ultimate parent and ultimate beneficial owner of the entity resides; and (c) if the relevant entity is incorporated outside the Islands, the competent authority of the relevant jurisdiction in which the entity is incorporated. Objects and Reasons International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Introduced Clause 5 also amends section 10 of the principal Law to give the Authority the power to provide the information provided to it under this Law as appropriate. A definition for the term \u201centity\u201d is provided so that in section 10 of the principal Law the reference is to entities incorporated or registered in the Cayman Islands. Clause 6 inserts a new section 13A which provides that if a person enters into an arrangement, the main purpose or one of the main purposes of which is to avoid any obligation under the principal Law, the arrangement is deemed not to have been entered into by the person and this Law is to have effect as if the arrangement had never been in existence. Clause 7 amends the Schedule to the principal Law to make changes to the definitions in light of the amendments made to the principal Law by this Bill. International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Arrangement of Clauses Introduced INTERNATIONAL TAX CO-OPERATION (ECONOMIC SUBSTANCE) (AMENDMENT) BILL, 2019 Arrangement of Clauses Clause 1.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_2\", \"num\": \"2.\", \"text\": \"Amendment of section 4 of the International Tax Co-operation (Economic Substance) 3. 4. 5. 6.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Clause 1 Introduced INTERNATIONAL TAX CO-OPERATION (ECONOMIC SUBSTANCE) (AMENDMENT) BILL, 2019 A BILL FOR A LAW TO AMEND THE INTERNATIONAL TAX CO-OPERATION (ECONOMIC SUBSTANCE) LAW, 2018 TO MAKE CHANGES TO THE ECONOMIC SUBSTANCE NOTIFICATION REQUIREMENTS AND THE REQUIREMENTS TO PROVIDE AND SHARE INFORMATION; AND FOR INCIDENTAL AND CONNECTED PURPOSES ENACTED by the Legislature of the Cayman Islands.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_1\", \"num\": \"1.\", \"text\": \"Short title 1. This Law may be cited as the International Tax Co-operation (Economic Substance) (Amendment) Law, 2019. 2. Amendment of section 4 of the International Tax Co-operation (Economic Substance) Law, 2018 - requirement to satisfy economic substance test 2. The International Tax Co-operation (Economic Substance) Law, 2018, in this Law referred to as the \u201cprincipal Law\u201d, is amended in section 4 as follows \u2014 (a) in subsection (2)(a) by deleting the words \u201cCayman Islands\u201d; and (b) in subsection (4) by deleting the words \u201cCayman Islands\u201d wherever they appear. Clause 3 International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Introduced\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_3\", \"num\": \"3.\", \"text\": \"Amendment of section 5 - guidance 3. The principal Law is amended in section 5(1) and (4) by deleting the words \u201cand with the approval of the Cabinet\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_4\", \"num\": \"4.\", \"text\": \"Amendment of section 7 - requirement to provide information 4. The principal Law is amended in section 7 as follows \u2014 (a) by repealing subsection (1) and substituting the following \u2014 \u201c(1) An entity shall notify the Authority annually of \u2014 (a) whether or not it is carrying on a relevant activity; (b) if it is carrying on a relevant activity, whether or not it is a relevant entity; (c) in the case of an entity that is tax resident in a jurisdiction outside the Islands \u2014 (i) the name and address of its immediate parent, ultimate parent and ultimate beneficial owner of the entity and any other information required to identify the immediate parent, ultimate parent and ultimate beneficial owner of the entity; (ii) the date of the end of its financial year; and (iii) the jurisdiction in which the entity is claiming to be tax resident and any other information required to support that claim; (d) in the case of a relevant entity that is carrying on relevant activity, the date of the end of its financial year, and (e) in the case of a relevant entity that is carrying on a relevant activity, the name and address of the officer who is responsible for providing information to the Authority, and shall provide appropriate evidence to support the information provided in the notification as may be required by the Authority.\u201d; (b) in subsection (4) \u2014 (i) inserting after paragraph (e) the following paragraph \u2014 \u201c(ea) the name and address of any person other than the relevant entity who is conducting the relevant entity\u2019s core income generating activities in relation to its relevant activity;\u201d; and (ii) in paragraph (f), by deleting the words \u201cCayman Islands\u201d; (c) by inserting after subsection (4), the following subsection \u2014 International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Clause 4 Introduced \u201c(4A) A relevant entity shall provide the Authority with appropriate evidence to support the information provided to the Authority under subsection (4) as may be required by the Authority.\u201d; (d) by inserting after subsection (6), the following subsection \u2014 \u201c(6A) Where under section 4(4), a person is conducting core income generating activities in relation to the relevant activity of a relevant entity, that person may verify the information provided to the Authority under subsection (4) within thirty days after the day on which the information is provided.\u201d; (e) by inserting after subsection (8), the following subsections \u2014 \u201c(8A) Where a relevant entity that is required to satisfy the economic substance test fails to prepare and submit to the Authority the report required under subsection (3) within the time specified in that subsection, the Authority shall by notice in writing impose a penalty of five thousand dollars and an additional penalty of five hundred dollars for each day during which the failure to comply continues. (8B) The Authority shall not impose a penalty under subsection (8A) after the earlier of the following \u2014 (a) one year after becoming aware of the contravention; or (b) six years after the contravention occurred. (8C) A penalty under subsection (8A) must be paid before the end of the period of thirty days commencing with the date mentioned in subsection (8D). (8D) That date referred to in subsection (8C) is the later of \u2014 (a) the date from which the penalty is due under subsection (8A); or (b) if a notice of appeal is given under subsection (8F), the date on which the appeal is finally determined or withdrawn. (8E) A penalty under subsection (8A) shall be paid into the general revenue of the Islands and may be recovered as a civil debt due to the general revenue of the Islands. (8F) A relevant entity that has a penalty imposed pursuant to subsection (8A) may, within thirty days after the notice is given under that subsection, appeal against the penalty to the Grand Court and such appeal shall act as a stay on the enforcement of the penalty. Clause 5 International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Introduced (8G) A relevant entity upon whom a penalty is imposed under subsection (8A) may appeal against the penalty on the ground that liability to a penalty does not arise. (8G) An appeal under this section may be made on questions of law or fact or both and the Grand Court may affirm or reverse the penalty or substitute its own penalty for that imposed by the Authority.\u201d; and (f) by inserting after subsection (9), the following subsection \u2014 \u201c(10) In this section \u201centity\u201d means \u2014 (a) a company that is \u2014 (i) incorporated under the Companies Law (2018 Revision); or (ii) a limited liability company registered under the Limited Liability Companies Law (2018 Revision); (b) a limited liability partnership that is registered in accordance with the Limited Liability Partnership Law, 2017; or (c) a company that is incorporated outside of the Islands and registered under the Companies Law (2018 Revision).\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"Amendment of section 10 - sharing of information 5. The principal Law is amended in section 10 as follows \u2014 (a) in subsections (1)(a) and (2)(a) by deleting the words \u201cparent company, ultimate parent company\u201d and substituting the words \u201cimmediate parent, ultimate parent\u201d; and (b) by inserting after subsection (2), the following subsections \u2014 \u201c(3) In the case of an entity that is tax resident in a jurisdiction outside of the Islands, the Authority shall, in accordance with relevant international standards and scheduled agreements, provide the information provided to it under this Law to the competent authority in \u2014 (a) the jurisdiction in which that entity is tax resident; (b) the jurisdiction in which the immediate parent, ultimate parent and ultimate beneficial owner of the entity resides; and (c) if the relevant entity is incorporated outside the Islands, the competent authority of the relevant jurisdiction in which the entity is incorporated. (4) The Authority may, in accordance with relevant international standards and scheduled agreements, provide any information provided to it under this Law as appropriate. International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Clause 6 Introduced (5) In this section \u201centity\u201d means \u2014 (a) a company that is \u2014 (i) incorporated under the Companies Law (2018 Revision); or (ii) a limited liability company registered under the Limited Liability Companies Law (2018 Revision); (b) a limited liability partnership that is registered in accordance with the Limited Liability Partnership Law, 2017; or (c) a company that is incorporated outside of the Islands and registered under the Companies Law (2018 Revision).\u201d.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Insertion of section 13A - anti-avoidance 6. The principal Law is amended by inserting after section 13, the following section \u2014 \u201cAnti-avoidance 13A. If a person enters into any arrangement, the main purpose or one of the main purposes of which is to avoid any obligation under this Law, the arrangement is deemed not to have been entered into by the person and this Law is to have effect as if the arrangement had never been in existence.\u201d. 7. Amendment of Schedule - construction of words and expressions 7. The principal Law is amended in the Schedule as follows \u2014 (a) in the definition of the words \u201cCayman Islands core income generating activities\u201d, by deleting the words \u201cCayman Islands core income generating activities\u201d and substituting the words \u201ccore income generating activities; (b) by deleting the definition of the words \u201cparent company\u201d; (c) by inserting in the appropriate alphabetical sequence the following definition \u2014 \u201c \u201cimmediate parent\u201d, in relation to an entity, means a person that owns directly twenty-five percent of the ownership interests in the entity.\u201d; and Clause 7 International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019 Introduced (d) in the definition of the words \u201cultimate parent company\u201d by deleting the word \u201cultimate parent company\u201d and substituting the words \u201cultimate parent\u201d. Passed by the Legislative Assembly the      day of , 2019. 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In the case of an\nentity that is tax resident in a jurisdiction outside the Islands, the nameand address of its\nimmediate parent, ultimate parent and ultimate beneficial owner of the entity. The\njurisdiction in which the entity is claiming to be tax resident and the supporting\ninformation is also required. The amendment also provides for the verification of any\noutsourcing of core income generating activities. A definition for the term \u201centity\u201d is\nprovided so that in section 7 of the principal Law the reference is to entities incorporated\nor registered in the Cayman Islands. Clause 4 also amends section 7 of the principal Law\nto give the Authority the power to impose a penalty for failure to comply with the\nrequirement to provide a report under section 7 of the principal Law.\nClause 5 amends section 10 of the principal Law to substitute references to the terms\n\u201cparent company\u201d and \u201cultimate parent company\u201d with references to the terms\n\u201cimmediate parent\u201d and ultimate parent\u201d. Clause 5 also adds a new subsection to\nsection 10. The new subsection imposes an obligation on the Authority, in the case of an\nentity that is tax resident in a jurisdiction outside of the Islands, in accordance with\nrelevant international standards and scheduled agreements, to provide the information\nprovided to it to the competent authority in \u2014\n(a)\nthe jurisdiction in which that entity is tax resident;\n(b)\nthe jurisdiction in which the immediate parent, ultimate parent and ultimate\nbeneficial owner of the entity resides; and\n(c)\nif the relevant entity is incorporated outside the Islands, the competent authority of\nthe relevant jurisdiction in which the entity is incorporated.\n\nObjects and Reasons\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\n\nPage 4\n Introduced\nc\n\nClause 5 also amends section 10 of the principal Law to give the Authority the power to\nprovide the information provided to it under this Law as appropriate.\nA definition for the term \u201centity\u201d is provided so that in section 10 of the principal Law\nthe reference is to entities incorporated or registered in the Cayman Islands.\nClause 6 inserts a new section 13A which provides that if a person enters into an\narrangement, the main purpose or one of the main purposes of which is to avoid any\nobligation under the principal Law, the arrangement is deemed not to have been entered\ninto by the person and this Law is to have effect as if the arrangement had never been in\nexistence.\nClause 7 amends the Schedule to the principal Law to make changes to the definitions in\nlight of the amendments made to the principal Law by this Bill.\n\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\nArrangement of Clauses\n\nc\n Introduced\nPage 5\n\nCAYMAN ISLANDS\n\nINTERNATIONAL TAX CO-OPERATION\n(ECONOMIC SUBSTANCE) (AMENDMENT)\nBILL, 2019\nArrangement of Clauses\nClause\nPage\n1.\nShort title ...................................................................................................................................7\n2.\nAmendment of section 4 of the International Tax Co-operation (Economic Substance)\nLaw, 2018 - requirement to satisfy economic substance test......................................................7\n3.\nAmendment of section 5 - guidance ...........................................................................................8\n4.\nAmendment of section 7 - requirement to provide information ....................................................8\n5.\nAmendment of section 10 - sharing of information ................................................................... 10\n6.\nInsertion of section 13A - anti-avoidance ................................................................................. 11\n7.\nAmendment of Schedule - construction of words and expressions ........................................... 11\n\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\nClause 1\n\nc\n Introduced\nPage 7\n\nCAYMAN ISLANDS\n\nINTERNATIONAL TAX CO-OPERATION\n(ECONOMIC SUBSTANCE) (AMENDMENT)\nBILL, 2019\n\nA BILL FOR A LAW TO AMEND THE INTERNATIONAL TAX CO-OPERATION\n(ECONOMIC SUBSTANCE) LAW, 2018 TO MAKE CHANGES TO THE ECONOMIC\nSUBSTANCE NOTIFICATION REQUIREMENTS AND THE REQUIREMENTS TO\nPROVIDE AND SHARE INFORMATION; AND FOR INCIDENTAL AND CONNECTED\nPURPOSES\nENACTED by the Legislature of the Cayman Islands.\n1.\nShort title\n1.\nThis Law may be cited as the International Tax Co-operation (Economic\nSubstance) (Amendment) Law, 2019.\n2.\nAmendment of section 4 of the International Tax Co-operation (Economic\nSubstance) Law, 2018 - requirement to satisfy economic substance test\n2.\nThe International Tax Co-operation (Economic Substance) Law, 2018, in this Law\nreferred to as the \u201cprincipal Law\u201d, is amended in section 4 as follows \u2014\n(a)\nin subsection (2)(a) by deleting the words \u201cCayman Islands\u201d; and\n(b) in subsection (4) by deleting the words \u201cCayman Islands\u201d wherever they\nappear.\n\nClause 3\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\n\nPage 8\n Introduced\nc\n\n3.\nAmendment of section 5 - guidance\n3.\nThe principal Law is amended in section 5(1) and (4) by deleting the words \u201cand\nwith the approval of the Cabinet\u201d.\n4.\nAmendment of section 7 - requirement to provide information\n4.\nThe principal Law is amended in section 7 as follows \u2014\n(a)\nby repealing subsection (1) and substituting the following \u2014\n\u201c(1) An entity shall notify the Authority annually of \u2014\n(a)\nwhether or not it is carrying on a relevant activity;\n(b) if it is carrying on a relevant activity, whether or not it is a\nrelevant entity;\n(c)\nin the case of an entity that is tax resident in a jurisdiction\noutside the Islands \u2014\n(i)\nthe name and address of its immediate parent, ultimate\nparent and ultimate beneficial owner of the entity and\nany other information required to identify the immediate\nparent, ultimate parent and ultimate beneficial owner of\nthe entity;\n(ii) the date of the end of its financial year; and\n(iii) the jurisdiction in which the entity is claiming to be tax\nresident and any other information required to support\nthat claim;\n(d) in the case of a relevant entity that is carrying on relevant\nactivity, the date of the end of its financial year, and\n(e)\nin the case of a relevant entity that is carrying on a relevant\nactivity, the name and address of the officer who is\nresponsible for providing information to the Authority,\nand shall provide appropriate evidence to support the information\nprovided in the notification as may be required by the Authority.\u201d;\n(b) in subsection (4) \u2014\n(i)\ninserting after paragraph (e) the following paragraph \u2014\n\u201c(ea) the name and address of any person other than the relevant\nentity who is conducting the relevant entity\u2019s core income\ngenerating activities in relation to its relevant activity;\u201d; and\n(ii) in paragraph (f), by deleting the words \u201cCayman Islands\u201d;\n(c)\nby inserting after subsection (4), the following subsection \u2014\n\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\nClause 4\n\nc\n Introduced\nPage 9\n\n\u201c(4A) A relevant entity shall provide the Authority with appropriate\nevidence to support the information provided to the Authority\nunder subsection (4) as may be required by the Authority.\u201d;\n(d) by inserting after subsection (6), the following subsection \u2014\n\u201c(6A) Where under section 4(4), a person is conducting core income\ngenerating activities in relation to the relevant activity of a\nrelevant entity, that person may verify the information provided to\nthe Authority under subsection (4) within thirty days after the day\non which the information is provided.\u201d;\n(e)\nby inserting after subsection (8), the following subsections \u2014\n\u201c(8A) Where a relevant entity that is required to satisfy the economic\nsubstance test fails to prepare and submit to the Authority the report\nrequired under subsection (3) within the time specified in that\nsubsection, the Authority shall by notice in writing impose a penalty\nof five thousand dollars and an additional penalty of five hundred\ndollars for each day during which the failure to comply continues.\n(8B) The Authority shall not impose a penalty under subsection (8A)\nafter the earlier of the following \u2014\n(a)\none year after becoming aware of the contravention; or\n(b) six years after the contravention occurred.\n(8C) A penalty under subsection (8A) must be paid before the end of the\nperiod of thirty days commencing with the date mentioned in\nsubsection (8D).\n(8D) That date referred to in subsection (8C) is the later of \u2014\n(a)\nthe\ndate\nfrom\nwhich\nthe\npenalty\nis\ndue\nunder\nsubsection (8A); or\n(b) if a notice of appeal is given under subsection (8F), the date on\nwhich the appeal is finally determined or withdrawn.\n(8E) A penalty under subsection (8A) shall be paid into the general\nrevenue of the Islands and may be recovered as a civil debt due to\nthe general revenue of the Islands.\n(8F) A relevant entity that has a penalty imposed pursuant to\nsubsection (8A) may, within thirty days after the notice is given\nunder that subsection, appeal against the penalty to the Grand Court\nand such appeal shall act as a stay on the enforcement of the\npenalty.\n\nClause 5\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\n\nPage 10\n Introduced\nc\n\n(8G) A relevant entity upon whom a penalty is imposed under subsection\n(8A) may appeal against the penalty on the ground that liability to a\npenalty does not arise.\n(8G) An appeal under this section may be made on questions of law or\nfact or both and the Grand Court may affirm or reverse the penalty\nor substitute its own penalty for that imposed by the Authority.\u201d;\nand\n(f)\nby inserting after subsection (9), the following subsection \u2014\n\u201c(10) In this section \u201centity\u201d means \u2014\n(a)\na company that is \u2014\n(i)\nincorporated under the Companies Law (2018 Revision);\nor\n(ii) a limited liability company registered under the Limited\nLiability Companies Law (2018 Revision);\n(b) a limited liability partnership that is registered in accordance\nwith the Limited Liability Partnership Law, 2017; or\n(c)\na company that is incorporated outside of the Islands and\nregistered under the Companies Law (2018 Revision).\u201d.\n5.\nAmendment of section 10 - sharing of information\n5.\nThe principal Law is amended in section 10 as follows \u2014\n(a)\nin subsections (1)(a) and (2)(a) by deleting the words \u201cparent company,\nultimate parent company\u201d and substituting the words \u201cimmediate parent,\nultimate parent\u201d; and\n(b) by inserting after subsection (2), the following subsections \u2014\n\u201c(3) In the case of an entity that is tax resident in a jurisdiction outside\nof the Islands, the Authority shall, in accordance with relevant\ninternational standards and scheduled agreements, provide the\ninformation provided to it under this Law to the competent\nauthority in \u2014\n(a)\nthe jurisdiction in which that entity is tax resident;\n(b) the jurisdiction in which the immediate parent, ultimate parent\nand ultimate beneficial owner of the entity resides; and\n(c)\nif the relevant entity is incorporated outside the Islands, the\ncompetent authority of the relevant jurisdiction in which the\nentity is incorporated.\n(4) The Authority may, in accordance with relevant international\nstandards and scheduled agreements, provide any information\nprovided to it under this Law as appropriate.\n\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\nClause 6\n\nc\n Introduced\nPage 11\n\n(5) In this section \u201centity\u201d means \u2014\n(a)\na company that is \u2014\n(i)\nincorporated under the Companies Law (2018 Revision);\nor\n(ii) a limited liability company registered under the Limited\nLiability Companies Law (2018 Revision);\n(b) a limited liability partnership that is registered in accordance\nwith the Limited Liability Partnership Law, 2017; or\n(c)\na company that is incorporated outside of the Islands and\nregistered under the Companies Law (2018 Revision).\u201d.\n6.\nInsertion of section 13A - anti-avoidance\n6.\nThe principal Law is amended by inserting after section 13, the following section \u2014\n\u201cAnti-avoidance\n13A. If a person enters into any arrangement, the main purpose or one of the\nmain purposes of which is to avoid any obligation under this Law, the\narrangement is deemed not to have been entered into by the person and\nthis Law is to have effect as if the arrangement had never been in\nexistence.\u201d.\n7.\nAmendment of Schedule - construction of words and expressions\n7.\nThe principal Law is amended in the Schedule as follows \u2014\n(a)\nin the definition of the words \u201cCayman Islands core income generating\nactivities\u201d, by deleting the words \u201cCayman Islands core income\ngenerating activities\u201d and substituting the words \u201ccore income\ngenerating activities;\n(b) by deleting the definition of the words \u201cparent company\u201d;\n(c)\nby inserting in the appropriate alphabetical sequence the following\ndefinition \u2014\n\u201c \u201cimmediate parent\u201d, in relation to an entity, means a person that\nowns directly twenty-five percent of the ownership interests in the\nentity.\u201d; and\n\nClause 7\nInternational Tax Co-operation (Economic Substance) (Amendment)\nBill, 2019\n\nPage 12\n Introduced\nc\n\n(d) in the definition of the words \u201cultimate parent company\u201d by deleting the\nword \u201cultimate parent company\u201d and substituting the words \u201cultimate\nparent\u201d.\n\nPassed by the Legislative Assembly the      day of\n\n, 2019.\n\nSpeaker\n\nClerk of the Legislative Assembly","akn_extracted_at":"2026-07-18 12:35:34.720431+00","cms_id":"2019-0029","law_type":"bill","year":"2019","number":"29","title":"International Tax Co-operation (Economic Substance) (Amendment) Bill, 2019","status":"bill"},"provenance":{"files":[{"file_id":"6999","expr_id":"2200","kind":"akn_xml","filename":"2019-0029.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/BILLS\/2019\/2019-0029\/2019-0029.akn.xml","content_md5":"be5a4308eb4b1a31973893c91eee3503","byte_size":"17471","http_last_modified":null,"fetched_at":"2026-07-18 12:35:34.774407+00"},{"file_id":"4399","expr_id":"2200","kind":"pristine_pdf","filename":"2019-0029.pdf","source_url":"\/cms\/images\/LEGISLATION\/BILLS\/2019\/2019-0029\/2019-0029.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/BILLS\/2019\/2019-0029\/2019-0029.pdf","content_md5":"318aa7ed54eb4c76c69dc3e896133055","byte_size":"672224","http_last_modified":null,"fetched_at":"2026-06-16 04:01:11.285502+00"},{"file_id":"4400","expr_id":"2200","kind":"working_pdf","filename":"2019-0029.pdf","source_url":"\/cms\/images\/LEGISLATION\/BILLS\/2019\/2019-0029\/2019-0029.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/BILLS\/2019\/2019-0029\/2019-0029.pdf","content_md5":"318aa7ed54eb4c76c69dc3e896133055","byte_size":"672224","http_last_modified":null,"fetched_at":"2026-06-16 04:01:11.285502+00"}],"paragraph_count":23,"latest_history":{"history_id":"270176","change_type":"UPDATE","changed_at":"2026-07-18 00:00:00+00","change_source":"MIGRATION_027","change_reason":"CMS-id-collision audit 2026-07-18: title corrected from the document's own PDF and\/or the (law_type, cms_id)-keyed official legislation.gov.ky listing."}},"quality":{"expr_id":"2200","doc_id":"2200","quality_state":"known_issue","quality_score":"51","needs_human_review":"t","deterministic_categories":"{duplicate_text,page_header_footer_noise,title_mismatch}","llm_categories":"{}","repair_actions":"{collapse_duplicate_text,strip_page_furniture,verify_title_metadata}","finding_severity_counts":"{\"high\": 1, \"medium\": 2}","finding_summary":"stored title is not visible in the opening extracted text; repeated line furniture detected: cayman islands x3; international tax co operation x3; introduced x10","assessed_at":"2026-06-22 15:29:46.695214+00","updated_at":"2026-06-22 15:29:46.695214+00"}}