The Marshall Islands adopted Economic Substance Regulations applicable from the 1st January 2019. However it is interesting to note that:
- it applies strictly to relevant activities (distribution and service center business, financing and leasing business, headquarters business, holding company business, intellectual property business, shipping business, banking business, and insurance business)
- holding company business is defined as pure equity holding company
- a pure equity holding company is subject to a reduced economic substance test
- the entities must provide the relevant information if requested by the Registrar
- it seems to apply to Master Series LLC only (and not each Series)
- an entity does not have to satisfy the economic substance requirement if the entity can claim tax residence elsewhere.