The playuzu casino bonus Substance (Companies and Limited Partnerships) Act, 2018 (the “playuzu casino bonus”) was passed on 1 January 2019, introducing playuzu casino bonus substance requirements in the British Virgin Islands (“playuzu casino bonus”) for certain BVI legal entities that are not tax “resident” in countries outside the BVI and carry on a “relevant activity” as further specified in the playuzu casino bonus. On 22 April 2019, the International Tax Authority (“ITA”) of the BVI issued a draft playuzu casino bonus Substance Code (the “Code”) to provide guidance and interpretation in respect of the playuzu casino bonus (for further information please see our earlier client briefing).
The draft Code then underwent a process of revision playuzu casino bonus ensuing months which has recently been concluded. A final version was issued by the ITA on 9 October 2019. Now renamed “Rules on playuzu casino bonus Substance” (the “playuzu casino bonus”), they are expected to become effective shortly, when a further amendment to the Beneficial Ownership Secure Search System playuzu casino bonus, as amended[1] (the “BOSS playuzu casino bonus”) playuzu casino bonus BVI is brought into force.
While the playuzu casino bonus reflect much of the content of the draft Code, some new points worth highlighting include the following.
Provisional Treatment of Tax Residency outside the playuzu casino bonus. An entity may apply to be treated as provisionally tax resident in a jurisdiction outside the BVI and submit evidence of this to the ITA within a “reasonable period”. The playuzu casino bonus now clarify that such period would typically not extend beyond two financial periods (inclusive of the financial period for which the entity has applied for provisional treatment). See paragraph 4.5 commenting on playuzu casino bonus 6 and 7.
Expenditure Incurred playuzu casino bonus BVI. Rule 11 now clarifies that “expenditure” (as used in the requirement, that entities subject to the playuzu casino bonus substance requirements must have adequate expenditure incurred in BVI, having regard to the nature and scale of the relevant activity, in section 8 of the playuzu casino bonus and section 10 of the BOSS playuzu casino bonus) means expenditure incurred in the operation of the relevant activity. See also paragraphs 7.8 to 7.11.
Liquidation of an Entity. Paragraph 10.8 states that it is expected that the playuzu casino bonus substance requirements will need to be complied with during the time that an entity is in liquidation.
Additional Filing Requirements. Certain additional information must now be provided to the registered agent of relevant entities for uploading to its database, including:
- Confirmation as to whether an entity carries on a relevant activity within the scope of the playuzu casino bonus;
- Residential address of each beneficial owner of an entity;
- Total expenditure incurred on the relevant activity and total number of employees engaged playuzu casino bonus relevant activity;
- Certain further information in respect of an entity carrying on intellectual property business.
For further information please reach out to your usual Campbells contact.