The BVI Economic Substance Act, 2018

2019-02-18 14:06:46


The BVI Economic Substance Act, 2018


涵盖公司范围 Companies in scope



Substance requirements are expected to apply to BVI entities that are tax resident in the BVI and which conduct relevant activities.

相关实体包括 A relevant entity includes:

1.     所有具法人资格的英属维尔京群岛税务居民所持有的英属维尔京群岛公司和有限合伙公司。非英属维尔京群岛的税务居民企业不在本范围内.

 All BVI companies and limited partnerships with legal personality (LPs) that are tax residents of BVI. Companies that are tax resident elsewhere outside of the BVI are not in scope.

2.     所有在英属维尔京群岛持法人资格并开展业务的外国公司和有限合伙公司。

All foreign companies and limited partnerships with LPs doing business in the BVI



Relevant activities identified by the EU and more recently by the OECD include:

²  银行业务     ²  Bank business
²  保险业务²  Insurance business
²  基金管理业务²  Fund management business
²  融资及租赁业务²  Finance and leasing business
²  总部业务²  Headquarter business
²  航运业务²  Shipping business
²  控股业务²  Holding business
²  知识产权业务²  Intellectual property business
²  分销和服务中心业务²  Distribution and service center business

对您的影响 How it could affect you



Broadly speaking, if BVI companies that are BVI tax resident are conducting any of the relevant activities listed above, then substance may be required; if not, additional substance should not be required.


如需要,现有公司在 2019 年 6 月 30 日前须遵照经济实质要求,在 2019 年 6 月 30 日之后的一年内履行汇报义务。

If required, existing companies will need to comply with economic substance requirements and meet the reporting obligation within one year of 30 June 2019.



New companies must comply with the economic substance requirement immediately and are required to meet the reporting obligations within one year as of the date of incorporation or formation.



We are awaiting further guidance from the BVI as to more detailed definitions of the relevant activities and also what substance might be required.


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