What is a
Cayman Exempted Company?

What makes the Exempted Company structure distinctive?

• 20-30 year tax-exemption undertaking. Renewable. During the period no Cayman income tax, capital gains tax or other direct tax on the Company's operations.
• No requirement for annual general meeting in Cayman. Board meetings can be held anywhere.
• No requirement for Cayman-resident directors.
• Flexible share structures. Different classes, redeemable shares, treasury shares all permitted.
• No name requirement to end in 'Limited' or 'Ltd'. Unique among offshore jurisdictions.
• Continuation in/out permitted. Can be redomiciled to/from other jurisdictions.

What is a Cayman Foundation Company?

A relatively recent (2017) Cayman vehicle that operates like a foundation while holding full corporate legal personality. Foundation Companies have no shareholders but are governed by a supervisor (or members). Increasingly used as the legal wrapper for DAOs and token-treasury governance because:

• The DAO has no traditional shareholders — Foundation Company is structurally aligned.
• Corporate legal personality protects participants from unlimited liability.
• Governance can be operated via the supervisor / members per the constitution.

This makes Foundation Company the institutional alternative to Marshall Islands DAO LLC for projects requiring traditional Cayman familiarity.

What is an Exempted Limited Partnership (ELP)?

An Exempted Limited Partnership is the global default vehicle for private equity, venture capital and hedge funds. The General Partner (GP) typically a Delaware LLC or another Cayman entity; the Limited Partners (LPs) are global institutional investors. The ELP framework is well-tested and globally accepted.

What is a Segregated Portfolio Company (SPC)?

An SPC is a single Cayman company with multiple legally-segregated portfolios. Each portfolio's assets and liabilities are ring-fenced from the others. Used for multi-strategy funds, multi-cell insurance structures, and series-based securitisations.

What are Cayman Exempted Companies typically used for?

• Private equity / venture capital funds — Cayman ELP + Delaware GP is the global default architecture.
• Hedge funds — Cayman Exempted Company as master fund; Delaware feeder for US tax-exempt LPs.
• DAO governance — Foundation Company as the legal wrapper for on-chain DAOs.
• Token issuance (institutional) — Exempted Company for institutional-VC-backed token issuances.
• Listed feeder vehicles — SPAC sponsors, listed real-estate vehicles.
• Captive insurance — SPC structures for multi-cell insurance arrangements.
• Multi-tier holding — top-tier in a large-cap international holding structure.

What is Cayman Economic Substance compliance?

The Cayman Economic Substance Act 2018 requires entities engaged in relevant activities to demonstrate substance in Cayman — qualified employees, premises, expenditure and core income-generating activities. Pure equity-holding companies face simplified requirements. Annual ES return is required.

What about the Cayman QDMTT consultation?

Cayman is consulting on implementing a Qualified Domestic Minimum Top-up Tax (QDMTT) in response to OECD Pillar Two. If implemented, Cayman would collect the Pillar Two top-up tax on in-scope groups' Cayman income (consolidated revenue at or above EUR 750M) rather than ceding it to foreign parent or sister jurisdictions through IIR/UTPR. Sub-threshold groups remain unaffected by Pillar Two.

How does Cayman compare to BVI?

Cayman is the institutional default — preferred by global LPs, VCs and listed-vehicle counterparties. BVI is the cost-efficient workhorse — preferred for SPVs and lean intra-group structures. Cayman costs roughly 2x BVI in setup and ongoing maintenance. The choice generally tracks the sophistication of the investor base.

What does “exempted” mean in a Cayman exempted company?

“Exempted” means the company conducts its business mainly outside the Cayman Islands and is exempt from requirements applying to ordinary resident companies. It can also obtain a tax-exemption undertaking — a government assurance that any future Cayman taxes will not apply to it, typically given for 20 years.

Why do funds and token issuers choose Cayman?

Cayman is the institutional default for investment funds and a leading choice for token-issuing structures because of its tax neutrality, flexible companies law, deep professional-services bench and acceptance by global investors, banks and exchanges.

Does a Cayman exempted company pay tax?

The Cayman Islands imposes no corporate income, capital gains or withholding tax on an exempted company. Owners may still face tax in their home jurisdictions on distributions or under CFC rules, and Cayman economic-substance requirements apply to certain relevant activities.