The Income Tax (Substance Requirements)(Implementation)
Regulations, 2018 as amended (the Substance
Regulations) came into force on 1 January 2019 and have
recently been further updated by The Income Tax (Substance
Requirements)(Implementation)(Amendment) Regulations, 2019 (the
Amendment Regulations), with effect from 1 August
2019. The Amendment Regulations have extended the scope of
the Substance Regulations to include all tax exempt bodies that
have been granted an exemption under paragraphs (3) and (5) of
Schedule 1 of the Income Tax (Exempt Bodies) (Guernsey) Ordinance,
1989 (as amended) (the Exempt Bodies
Ordinance). In addition, the Amendment Regulations
clarify the scope of the Substance Regulations in relation to IP
Assets and High Risk IP Companies – the balance of this note
focuses on the change in status of tax exempt bodies.
