The economic substance regime has continued to develop, with the most notable change being the amendment to the definition of the ‘relevant activity’ of ‘fund management’, which was effective from 1 January 2022. As a result of the amendments, an entity will be carrying on the ‘relevant activity’ of ‘fund management’ if it manages investments for an investment fund, as defined under the Investment Funds Act 2006 (as amended), whether or not it is required to be licensed under the Investment Business Act 2003 (as amended) and will therefore include all entities even if they do not have a physical presence in Bermuda.
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