Regulatory Blog

The BVI Financial Investigation Agency (Returns) Order, 2025, has been published, introducing a structured framework for the submission of returns by Designated Non-Financial Businesses and Professions and Non-Profit Organisations. This Order, effective from 27 November 2025, clarifies reporting obligations and establishes a clear legal context for compliance. The Order, gazetted as Statutory Instrument No. 99 of 2025, formalises these requirements into law.

On 3 December 2025, the Department for International Tax Cooperation announced the activation of the Country-by-Country Reporting functionality on the DITC Portal. This functionality is effective as of 3 December 2025. This update is critical for Multinational Enterprise Groups with Cayman Islands Constituent Entities.

On 27 November 2025, the Cayman Islands published two pivotal regulations aimed at improving global tax transparency: the Crypto-Asset Reporting Framework and amendments to the Common Reporting Standard. Effective 1 January 2026, these regulations are designed to combat tax evasion and the misuse of virtual assets.

On 20 November 2025, the British Virgin Islands International Tax Authority announced that Economic Substance reporting obligations will transition from the Beneficial Ownership Secure Search System to the Virtual Integrated Registry Regulatory General Information Network portal. The ITA has confirmed that the new VIRRGIN ES filing portal is in its final stages of preparation and will be deployed for filings due in 2026.

On 24 July 2025, a key bill of law was brought before the Luxembourg Parliament introducing a proposal designed to rejuvenate the carried interest tax framework for managers of Luxembourg alternative investment funds. With its sights set on fiscal year 2026, this initiative intends to modernise the tax regime, enhancing Luxembourg’s ability to attract talented professionals in the competitive AIF sector.

The British Virgin Islands and Cayman Islands are leading jurisdictions for establishing regulated trustee businesses. Their regulatory oversight, tax-neutral environments and innovative trust structures continue to attract individuals and entities seeking to operate within a well-regulated trust framework.

During the last G7 summit a "side-by-side" system was proposed to address concerns raised by the United States regarding Pillar 2.

On 24 June 2025, a decision by the Judicial Committee of the Privy Council overturned Jersey’s first-ever declaration of incompatibility under the Human Rights (Jersey) Law 2000 in a case that focussed on the International Co-operation (Protection from Liability) (Jersey) Law 2018, which limits costs and damages against public authorities acting in good faith to fulfil international requests.

The BVI International Tax Authority recently hosted a Common Reporting Standards webinar, introducing substantial updates to CRS compliance and upcoming regulatory requirements for financial institutions. These changes, coupled with key filing deadlines for 2025, highlight the heightened focus on regulatory compliance within the BVI.

On 29 January 2025, Luxembourg’s tax authority published Circular L.I.R. n° 164/1, replacing the guidelines issued in 1998. This development modernises the rules for determining interest rates applicable to shareholder current accounts, introducing critical changes grounded in the arm’s length principle.

On 17 February 2025, the Government of Bermuda released its third consultation paper on the Corporate Income Tax Act 2023, focussing on provisions to ensure the effective administration of the CIT Act. This follows a careful review of feedback from the first two consultations, further refining the proposals to strike a balance between ease of administration and taxpayer compliance costs and robust tax collection and liability determination mechanisms. The consultation closes on 10 March 2025, and stakeholders are invited to submit their comments and suggestions via email.

On 12 December 2024, the Cyprus House of Representatives approved the implementation of a global minimum tax law in Cyprus for multinational enterprise groups and large domestic groups, aligning with the EU Pillar Two Directive 2022/2523. The GMT Law establishes a minimum effective tax rate of 15 per cent for MNEs with annual consolidated revenues exceeding €750 million. The GMT Law is currently in force as it was published in the Official Gazette of the Republic of Cyprus on 18 December 2024.