Clients should be aware that, notwithstanding timely provision of their information to their registered agent, ongoing technical issues with the VIRRGIN platform are currently preventing registered agents from completing certain economic substance filings on their behalf. The ITA has acknowledged that these system-wide errors continue to affect the submission of economic substance declarations and related filings, meaning that some entities may find themselves unable to comply with their statutory filing obligations despite having taken all necessary steps on their end.
In recognition of these difficulties, the ITA has confirmed that the application of late filing penalties continues to be suspended until the system issues are resolved. The ITA has indicated that further notification will be provided to the industry in advance of the resumption of penalties. This provides a degree of practical relief for affected entities, as penalties will not be applied during the period in which filings cannot be completed due to system errors.
While the penalty suspension offers welcome reassurance, clients should note that it does not remove the underlying statutory obligation to file. Clients should ensure that they have submitted all required information to their BVI registered agent promptly so that filings can be made as soon as the system issues are resolved. It is also prudent to retain records of when information was provided to the registered agent, as this may be relevant in the event of any future queries regarding the timeliness of compliance.
Our Regulatory team is actively monitoring the VIRRGIN transition and related ITA communications. We are available to assist clients in understanding their current filing position, confirming whether their economic substance declarations have been affected by the system issues, and ensuring that filings are submitted as soon as the platform permits. Please contact your usual Maples Group representative for further guidance.
