Marie-Claire Fudge
Partner | Legal
British Virgin Islands
Marie-Claire Fudge
Partner
British Virgin Islands
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Key regulatory filing deadlines for BVI funds in 2024
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These are the key regulatory filing dates for BVI funds, including incubator funds, approved funds, private funds, professional funds, public funds and private investment funds.
Our BVI lawyers work closely with our corporate and fiduciary professionals at Ogier Global. If you have any questions or require assistance with the matters outlined, contact your usual Ogier contact or one of the team listed below.
Incubator funds
|
Filing requirement |
Date due |
Notes |
|
Semi-annual return filings
|
By 31 January 2024 and 31 July 2024 |
Semi-annual returns must be filed with the BVI Financial Services Commission (the Commission) in the prescribed form and provide details of the following, as at 31 December/30 June (as relevant) of the prior year:
In addition, the 31 January semi-annual return needs to include:
|
|
Unaudited financial statements
|
Within 6 months of financial year end (ie by 30 June 2024 for funds with a 31 December 2023 year end)
|
In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts.
Extension and exemption requests must be submitted to the Commission within six months after the relevant financial year end. The maximum extension permitted under law is six months.
|
|
FATCA/CRS reporting
|
Annual reporting submission deadline for FATCA and CRS is 31 May each year
|
Filings are made on the International Tax Authority's reporting portal: BVIFARS - BVI ITA |
|
Economic substance
|
Annual self-certification due within six months of the end of the applicable reporting period
|
Self-certifications are submitted via the fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).
An incubator fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation.
|
Approved funds
|
Filing requirement |
Date due |
Notes |
|
Annual return filings
|
By 31 January 2024 |
Annual return must be filed with the Commission in the prescribed form provide details of the following, as at 31 December of the prior year:
In addition, the return needs to include:
|
|
Unaudited financial statements
|
Within six months of financial year end (ie by 30 June 2024 for funds with a 31 December 2023 year-end)
|
In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts.
Extension and exemption requests must be submitted to the Commission within six months after the relevant financial year end. The maximum extension permitted under law is six months.
|
|
FATCA/CRS reporting
|
Annual reporting submission deadline for FATCA and CRS is 31 May each year
|
Filings are made on the International Tax Authority's reporting portal: BVIFARS - BVI ITA |
|
Economic substance
|
Annual self-certification due within six months of the end of the applicable reporting period
|
Self-certifications are submitted via the fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).
An approved fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation.
|
Professional and private funds
|
Filing requirement |
Date due |
Notes |
|
Mutual funds annual return (MFAR) filing
|
On or before 30 June 2024 |
MFAR filing is undertaken via a dedicated portal: BVIFSC Mutual Funds Annual Reports Registration on the portal is required, if not previously done.
|
|
Audited financial statements
|
Within six months of financial year end (ie by 30 June 2024 for funds with a 31 December 2023 year-end)
|
In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts.
Extension and exemption requests must be submitted to the Commission within six months after the relevant financial year end. The maximum extension permitted under law is nine months.
|
|
FATCA/CRS reporting
|
Annual reporting submission deadline for FATCA and CRS is 31 May each year
|
Filings are made on the International Tax Authority's reporting portal: BVIFARS - BVI ITA |
|
Economic substance
|
Annual self-certification due within six months of the end of the applicable reporting period
|
Self-certifications are submitted via the fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).
Professional and private funds will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation.
|
Public funds
|
Filing requirement |
Date due |
Notes |
|
Mutual funds annual return (MFAR) filing
|
On or before 30 June 2024 |
MFAR filing is undertaken via a dedicated portal: BVIFSC Mutual Funds Annual Reports Registration on the portal is required, if not previously done.
|
|
Audited financial statements
|
Within six months of financial year end (ie by 30 June 2024 for funds with a 31 December 2023 year-end)
|
In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts.
Extension and exemption requests must be submitted to the Commission within six months after the relevant financial year end (or three months after the relevant financial year end if the public fund has conducted business during the financial year). The maximum extension permitted under law is six months.
|
|
FATCA/CRS reporting
|
Annual reporting submission deadline for FATCA and CRS is 31 May each year
|
Filings are made on the International Tax Authority's reporting portal: BVIFARS - BVI ITA |
|
Economic substance
|
Annual self-certification due within six months of the end of the applicable reporting period
|
Self-certifications are submitted via the fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).
A public fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation.
|
Private investment funds
|
Filing requirement |
Date due |
Notes |
|
Audited financial statements
|
Within six months of financial year end (ie by 30 June 2024 for funds with a 31 December 2023 year-end)
|
In limited circumstances, it is possible to request an extension to the filing deadline or an exemption from filing such accounts.
Extension and exemption requests must be submitted to the Commission within 6 months after the relevant financial year end. The maximum extension permitted under law is 9 months.
|
|
FATCA/CRS reporting
|
Annual reporting submission deadline for FATCA and CRS is 31 May each year
|
Filings are made on the International Tax Authority's reporting portal: BVIFARS - BVI ITA |
|
Economic substance
|
Annual self-certification due within six months of the end of the applicable reporting period
|
Self-certifications are submitted via the fund's BVI registered agent by making a filing on the BVI's Beneficial Ownership Secure Search System (BOSS).
A private investment fund will be considered to be undertaking "investment funds business" for the purposes of the BVI's economic substance legislation, which is not a relevant activity for the purposes of that legislation.
|
Key contacts
-
-
Simon Schilder
Partner | Legal
British Virgin Islands
Simon Schilder
Partner
British Virgin Islands
-
Tim Clipstone
Partner | Legal
British Virgin Islands, Guernsey
Tim Clipstone
Partner
British Virgin Islands, Guernsey
-
Michael Killourhy
Partner | Legal
British Virgin Islands
Michael Killourhy
Partner
British Virgin Islands
-
Kate Hodson 凯特 ·赫臣
Partner and Head of ESG (Legal) 合伙人 | Legal
Hong Kong
Kate Hodson 凯特 ·赫臣
Partner and Head of ESG (Legal) 合伙人
Hong Kong
-
Nicholas Plowman 包乐文
Partner 合伙人 | Legal
Hong Kong
Nicholas Plowman 包乐文
Partner 合伙人
Hong Kong
-
Richard Bennett
Partner | Legal
London, Hong Kong
Richard Bennett
Partner
London, Hong Kong
-
David Fowler
European Head of Fund Administration | Corporate and Fiduciary
London
David Fowler
European Head of Fund Administration
London
-
Monique Adams
Managing Director | Corporate and Fiduciary
British Virgin Islands
Monique Adams
Managing Director
British Virgin Islands
About Ogier
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Disclaimer
This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.
Regulatory information can be found under Legal Notice
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