Recently as part of on-going international initiatives, a large
number of international finance centres (including Jersey,
Guernsey, BVI and Cayman) have passed new laws requiring companies
which are tax resident in such centres and also conducting certain
types of activities to demonstrate that they have an adequate level
of physical substance and operations in those centres. The
fundamental scope and principles are the same in each of the
relevant centres, although there are some interesting areas of
difference which are beginning to emerge in the application of
certain specific aspects of the regimes between different
centres.
The following article sets out a brief overview of the new
substance regime with a particular focus on its application to
private wealth structures. Although the article refers specifically
to Jersey, the comments are directly applicable to Guernsey and the
general principles can also be applied in relation to BVI and
Cayman structures
