• Staff

Cayman amends ES Guidance V.2.0

Updated: Mar 10, 2020

The Department for International Tax Cooperation (DITC) wishes to advise industry of the amendment to Guidance v2.0, to reflect the changes made by the International Tax Co-Operation (Economic Substance) (Amendment of Schedule) (No. 3) Regulations, 2019.

Guidance 2.0 is amended with immediate effect.


Click here to read the amendment.


Economic Substance For Geographically Mobile Activities

AMENDMENT TO GUIDANCE 2.0

Issued pursuant to section 5 of The International Tax Co-operation (Economic Substance) Law, 2018 as amended (“ES Law”)

Date of Amendment Issue: 17 September 2019


Guidance 2.0 is amended with immediate effect, as follows:


Section I

Page 2: A 3 Summary of the ES Law

The words “,if carried on by a relevant entity” are deleted where they occur after the words “Cayman Islands CIGA means activities that are of central importance to a relevant entity in terms of generating relevant income and which”.


Page 4: B 2 2019 ES Regulations

  • (a) The words “and the International Tax Co-Operation (Economic Substance) (Amendment of Schedule) (No.3) Regulations, 2019 came into force on the 10 September 2019 (“2019 ES Regulations No. 3”)” are inserted after the words “(“2019 ES Regulations No.2”)”.

  • (b) The words “(n) MNE Group” are added to the list of defined terms.

  • (c) The words “and the ES Regulations No.3” are inserted in the last paragraph after the words “ES Regulations No.2”.


Section II

Page 6: A 2 Scope of the ES Law

The definition of “domestic company” is amended as follows: