At the time of writing, one of the most significant matters
facing the Channel Islands investment management sector (and in
fact, offshore business as a whole) is the question of economic
substance for companies that are tax resident in the Islands.
The challenge facing this writer is that this is such a fast
developing issue that circumstances and information available will
have changed enormously by the time of publication. Proposals are
due to be lodged for legislation in Jersey by 23 October 2018 and
in both jurisdictions it is anticipated that changes to corporate
tax residency rules will be in place with effect from 1 January
2019.
Some things however are already determined: in response to
requests from the EU Code of Conduct Group (Business Taxation)
(COCG) and with the threat of being placed on an EU blacklist as a
non-co-operating jurisdiction, Guernsey and Jersey gave high
level government commitments to make the necessary changes to
ensure companies have
