The rapid deployment of measures to prevent the spread of
COVID-19 (Coronavirus) are having an impact on how companies
continue to meet their regulatory obligations. Concerns have arisen
that those measures, such as restrictions on travel and voluntary
and mandatory social distancing, could cause difficulties for
companies required to satisfy the economic substance test in
Guernsey.
Under the Income Tax (Substance Requirements) (Implementation)
Regulations, 2018, as amended, certain companies that are tax
resident in Guernsey must satisfy the economic substance test.
Companies that are tax resident in Guernsey include companies that
are registered, or managed and controlled, in the Island. Part of
the economic substance test is for companies to demonstrate that
they are directed and managed, and performing core income
generating activities, in Guernsey in respect of their relevant
activities for economic substance. The di ected and managed part of
the economic
