Dear Industry,

You would have recently seen a gazette with a Bill entitled "Economic Substance (Companies and Limited Partnership) (Amendment) Act, 2021 (the "amended law").

The amended law will extend the economic substance regime to limited partnerships without legal personality (presently, those with legal personality are already in scope). This should come as no surprise. The amended law must be passed by the end of June 2021. The purpose of this email is to advise you on timing.

As a result of on-going negotiations with the EU, the amended law will have a transitional period of 6 months for existing limited partnerships without legal personality. However, legal partnerships without legal personality that are formed on or after 1 July 2021 (i.e., new ones) will be subject to the amended law right away.

The timing sequence is similar to the treatment of entities when the principal law initially came into effect except that, in that case, industry members had a draft law and Bill well ahead of it taking effect. Therefore, with the amended law, we wish to give relevant persons as much notice as possible.