February 24, 2020

On 18 February, 2020, the Council of the European Union (the “EU Council”) added the Cayman Islands to the EU’s official list of non-cooperative jurisdictions, commonly referred to as the “EU blacklist”.   While the Cayman Islands government has already initiated the process of attempting to remove the jurisdiction from the blacklist, it is possible that the EU Council’s measure will lead to increased disclosure requirements for Cayman Islands vehicles and their investors to EU tax authorities, and might even – in a worst case scenario - impact the ability of certain funds to repatriate investment proceeds without additional withholding or other adverse tax measures being imposed by relevant EU Member States.

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