Economic Substance

Economic substance laws have been adopted by the BVI, Cayman Islands, Guernsey and Jersey, requiring certain entities which are tax resident in one of the islands to be directed and managed and to carry out income generating activities in that island. The laws apply to a wide range of activities, including fund management, banking, insurance and certain arrangements between group companies. Whatever your business, we have experts in each of our jurisdictions who can help assess whether you are affected and, if so, ensure that you are compliant.

Our services include:

  • General advice, including assessing the application of substance law to your business
  • Economic substance audits
  • Direction and management reviews
  • Outsourcing analysis
  • Reporting obligations
  • Ongoing compliance
  • They function as a City firm and give good quality advice to clients.
    Chambers 2015
News/Experience
Jersey and Guernsey satisfy the EU on fair taxation and are confirmed as co-operative jurisdictions

Both Jersey and Guernsey fulfilled commitments made in 2017 to introduce substance measures to meet European expectations on fairness of taxation by the end of 2018 and have now been formally confirmed as 'cooperative jurisdictions'.

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Five steps to compliance with the Cayman Economic Substance test
Economic Substance 15 Jan 2019 Cayman Islands

The Cayman Islands (‘Cayman’) International Tax Co-operation (Economic Substance) Law, 2018 (‘Law’) and International Tax Co-operation (Economic Substance) (Prescribed Dates) Regulations, 2018 (‘Regulations’) came into force on 1 January 2019. Official Gui...

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Cayman economic substance legislation now in force
Corporate & Commercial Economic Substance 03 Jan 2019 Cayman Islands

As expected, the Cayman Islands International Tax Co-operation (Economic Substance) Law, 2018 came into force on 1 January 2019.

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Cayman economic substance legislation expected to be in force by 1 January 2019
Regulatory & Compliance Economic Substance 18 Dec 2018 Cayman Islands

The Cayman Islands Legislative Assembly is scheduled to debate The International Tax Co-operation (Economic Substance) Bill, 2018 in December 2018.

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Insights
Substance rules: top tips for companies
Briefings | 17 Jun 2019

New rules on economic substance came into effect on 1 January 2019 in the BVI, Cayman Islands, Guernsey and Jersey. Our experts have put their heads together and come up with their top tips for any company incorporated, registered or tax resident in one of ...

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Substance rules: top tips for corporate services providers
Briefings | 17 Jun 2019

New rules on economic substance came into effect on 1 January 2019 affecting companies and certain types of partnerships incorporated, registered or tax resident in the BVI, Cayman Islands, Guernsey or Jersey. Clients are looking to their corporate service ...

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Economic substance laws – multi-jurisdiction comparison
Briefings | 13 Jun 2019

In response to European Union requirements, many offshore jurisdictions have enacted legislation requiring certain tax resident entities to demonstrate sufficient economic substance in the relevant jurisdiction. This table gives a high-level overview and co...

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In a nutshell: BVI's Economic Substance Law
Briefings | 10 Jun 2019

The BVI (like many other offshore jurisdictions) has put in place a law requiring certain entities which are tax resident in the BVI to demonstrate that they have sufficient 'economic substance' in the BVI to show they are a true tax resident if they carry ...

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In a nutshell: Cayman Islands' Economic Substance Law
Briefings | 06 Jun 2019

The Cayman Islands has joined a global effort to establish an international standard for tax residence of entities doing business in a jurisdiction to avoid the Harmful Tax Practice of Base Erosion and Profit Shifting. Cayman has put in place a law requirin...

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In a nutshell: Jersey's Economic Substance Law
Briefings | 06 Jun 2019

Jersey (like many other offshore jurisdictions) has put in place a law requiring certain companies which are tax resident in Jersey to demonstrate that they have sufficient 'economic substance' in Jersey; this is known as the Taxation (Companies - Economic ...

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Economic substance rules in the Channel Islands
Briefings | 13 Feb 2019

This briefing aims to give a brief overview of what the new substance rules will entail for those companies tax resident in Guernsey or Jersey.

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