Bahrain and the United Arab Emirates have reportedly implemented economic substance requirements with effect from 1 January 2019 in order to comply with BEPS Action 5. The substance requirements are in line with requirements introduced by other low/no-tax jurisdictions such as Bermuda, the Cayman Islands, Jersey, etc., and include: Companies engaged in relevant activities must be managed and controlled in the respective jurisdiction; The core income generating activities for the relevant activities must be performed in the respective jurisdiction, with certain rules for outsourcing; and The company must have an adequate number of qualified employees, incur adequate expenditure, and have...