Our Response to the COVID-19 Pandemic

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Annual returns and economic substance notifications
The Registrar of Companies ("ROC") and the Department for International Tax Cooperation ("DITC") have extended the deadlines for entities to complete their annual returns and economic substance notification filings.

The annual return filing deadline has been extended until 30 June 2020. The extension will apply to all companies, including limited liability companies and foundation companies. Penalties for failure to file will come into force on 1 July 2020.

As a result of the annual return extension for companies, the deadline for economic substance notification filings is now 30 June 2020. Note, that the economic substance notification will remain a prerequisite for companies successfully filing an annual return.

In addition to the filing extension, ROC will accept affidavits or other documents that have been notarised or certified online or utilising audio-video technology during this time.

The General Registry, which incorporates the ROC, previously gave a one-month extension for beneficial ownership submissions. The extension went into effect on 23 March and will cease on 20 April 2020. The reprieve allows corporate service providers ("CSPs") to retrieve information from their overseas clients, while giving the Government’s Beneficial Ownership digital platform time to come online and for CSPs to transition to making electronic filings.

CIMA regulatory filings
The Cayman Islands Monetary Authority ("CIMA") is allowing an extension for regulatory filings as shown in the list within CIMA’s Notice. Also, notably:

>> CIMA’s inspection programme has become primarily desk-based with the scope of some inspections being narrowed. All meetings will take place by teleconference. In exceptional circumstances, CIMA will postpone planned reviews. However, doing this will require special dispensation.

>> CIMA will accept affidavits or other documents that have been notarised or certified via the DocuSign process or utilising audio-video technology during this time. As part of its business continuity plan, CIMA is committed to delivering full operations and services to the financial services industry. However, licensees and registrants are reminded to utilise email as the primary contact method.

These are the latest Cayman Islands measures to help the financial services industry in the face of COVID-19. We will advise further in the event of any updates.

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The Covid-19 crisis is upon us but what does this mean in terms of legal responsibilities relating to a business property? When considering the implications of the current Covid-19 public health crisis from a property perspective as either a landlord or a tenant, the lease should always be the starting point. It governs the contractual relationship between the parties and, pending the enactment of specific legislation altering the contractual obligations of the parties, the contractual provisions of the lease shall prevail.

Some of the key lease provisions likely to come into sharp focus resulting from the forced closure of non-essential businesses are the rent and keep open clauses.

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As cases of Covid-19 continue to spread the Irish Government has ordered all non-essential businesses to close.

In this advisory we explain the new measures which are designed to support workers and ease the burden on businesses if employees cannot attend work due to the impact of Covid-19. 

Updated 27 March

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