Economic Substance Return

Please complete this Economic Substance Return for Pure Equity Holding Companies, on behalf of the below named entity, with this information relating to International Tax Co-Operation (Economic Substance) Law ("ES Act"), as amended.

For more guidance on the data to be submitted in each field, please refer to the Sample Economic Substance Return ES Return PEHC sample

Should you require additional information on the Economic Substance regulations, guidance can be found at: Economic Substance Guidance. Any other laws referenced can be found at: https://www.ditc.ky/es/es-legislation-resources/ or https://www.cima.ky/laws-and-regulations.

Any references to "company" shall be interpreted to include "partnership"."

Client Reference Number(Required)

Incorporation/Registration Number(Required)

Relevant Entity ("Entity") Name(Required)

Overview

Period Start Date (i.e. start of financial year)(Required)

Period End Date (i.e. end of financial year)(Required)

Please confirm the Entity met the definition of a "Pure Equity Holding Company" as outlined in the ES Act, as amended, during the reporting period(Required)

Pure equity holding company means a company that only holds equity participations in other entities and only earns dividends and capital gains. As part of the functions of a pure equity holding company, activities may include, for example, ownership of a bank account, governance decisions, entering into contractual arrangements with professionals or other service providers and the payment of fees and expenses.

Relevant Income

Currency used to complete this ES Return.(Required)

Total Annual Income for the Period - Insert Monetary Amount.(Required)

Means total annual gross income of the Entity (i.e. not limited to relevant income).

Total Relevant Income for the Period - Insert Monetary Amount.(Required)

Means, in relation to an Entity, all of that Entity's gross income from its relevant activities and recorded in its books and records under applicable accounting standards. For the avoidance of doubt, relevant income for the purposes of the ES Act is gross income and not accounting income/profit. Gross income is equal to gross receipts/gross revenue, whether in the form of cash or property, which the Entity derived from its pure equity holding company business.

Types of Income

Total dividend income for the Period - Insert amount.(Required)

Dividend income will be interpreted to encompass any income payments made to a pure equity holding company in respect of equity participations and will include distributions made by non-corporate entities that are equivalent to dividends.

Total capital gains for the Period - Insert amount.(Required)

Change in the asset value over the holding period, as included in your financial statements/books of account. This may include losses.

Total Incidental Income for the Period - Insert amount(Required)

i.e. Occasional, minor activity with no profit making purpose, for example, incidental interest earned on a bank account balances. Other examples can be found in the Economic Substance Guidance Sector Specific Guidance on Holding Company Business (page 66).

Entity Details

Is the Entity a constituent entity of an MNE Group, for the purposes of the Country-by-Country Reporting (CbCR) framework?(Required)

Means any group that includes two or more enterprises for which the tax residence is in different jurisdictions or includes an enterprise that is resident for tax purposes in one jurisdiction and is subject to tax with respect to the business carried out through a permanent establishment in another jurisdiction. Means notification and filing requirements by Ultimate Parts or Surrogate Parents as detailed in the Tax Information Authority (International Tax Compliance) (Country-By-Country Reporting) Regulations (as amended)

Name of MNE Group, if different from Entity name

Immediate Parent

How many Immediate Parents does the Entity have?(Required)

Means, in relation to an entity, a corporate or non-corporate entity that owns directly twenty-five percent or more of the ownership interest or voting rights in the entity;

IMMEDIATE PARENT DETAILS - Please complete for each entity

Name of entity(Required)

TIN or Similar(Required)

TIN issued by(Required)

Jurisdiction of tax residence(Required)

Identification Number other than TIN(Required)

Type of Identification Number(Required)

Jurisdiction that issued other Identification Number(Required)

Legal Address Type(Required)

Country(Required)

Street(Required)

City(Required)

Other

Please provide any other information that the Entity considers material in determining that it has adequate substance in the Islands for the Period. If there has been a change to your relevant activity status, please include a reason here.(Required)

Ultimate Parent

Does the Entity have an Ultimate Parent entity?(Required)

Means a Constituent Entity of a Group that meets the following criteria - (a) it owns directly or indirectly a sufficient interest in one or more other Constituent Entities of the Group such that it is required to prepare Consolidated Financial Statements under accounting principles generally applied in its jurisdiction of tax residence, or would be so required if its equity interests were traded on public securities exchange in its jurisdiction of tax residence; and (b) there is no other Constituent Entity of the Group that owns directly or indirectly an interest described in paragraph (a) (above) in the first mentioned Constituent Entity.

Name of entity(Required)

TIN or Similar(Required)

TIN issued by(Required)

Jurisdiction of tax residence(Required)

Identification Number other than TIN(Required)

Type of Identification Number(Required)

Jurisdiction that issued other Identification Number(Required)

Legal Address Type(Required)

Country(Required)

Street(Required)

City(Required)

Other

Please provide any other information that the Entity considers material in determining that it has adequate substance in the Islands for the Period. If there has been a change to your relevant activity status, please include a reason here.(Required)

Financial Statements / Books of Account i

The Entity should provide appropriate documents (i.e. financial statements or books of account) that give a true and fair view of the state of the Entity's affairs and to explain its transactions. For the avoidance of doubt, the Authority does not expect underlying documents such as contracts and invoices. Furthermore for an Entity where only consolidated accounts are prepared, the documentation used to prepare the consolidated accounts and showing the Entity's affairs, would be sufficient. Any financial statements or books of account provided should be in English/English translation/ English equivalent including main points.

It is a requirement to submit a copy of the Entity's financial statements or books of account for the relevant entity's financial year. We kindly request that you send your financial statements or books of account for the financial year indicated above to your regular contact at Highvern, if these have not already been provided. If these are not received by Highvern before the deadline for your economic substance return submission, we will be unable to file your return and your company may be subject to regulatory penalties.

Declarations*

By submitting this ES Return, the Entity:

(1) Confirms that all information in this ES Return is accurate; and
(2) Acknowledges that there are sanctions for knowingly or wilfully supplying false or misleading information under section 13(2) of the ES Act

As a director of the Entity, I hereby authorise Highvern to file the Entity's Economic Substance Return with Tax Information Authority, or any other authority as may be required by act, based on the information previously provided. I understand that Highvern will use this information on an ongoing annual basis unless advised otherwise, and I undertake to advise Highvern promptly in the event of any changes to this information. I acknowledge and accept there are sanctions for providing inaccurate information and I confirm that the entity will indemnify Highvern for any liability that may result from the submission of inaccurate information. I also acknowledge Highvern makes the submission without undertaking any investigation or verification of the information provided.

DATA PROTECTION

The information you provide in response to this form will be processed for the purposes described above, in accordance with the General Data Protection Regulation and/or equivalent Data Protection legislation depending on the relevant jurisdiction. For more information about how we process your data, please see Highvern’s privacy statement which can be found at www.highvern.com/privacy-statement/

PURPOSE OF FORM AND INFORMED CONSENT

This form should be completed by all entities and structures required to comply with the / Economic Substance Regime in the Cayman Islands. Where you are providing information relating to other data subjects, you confirm that you have obtained the necessary informed consent for such disclosure.

Name(Required)

Date(Required)

Services

Services

Economic Substance Return