Like other offshore jurisdictions, Guernsey has implemented
legislative economic substance requirements, which came into force
on 1 January 2019, to meet a commitment to address concerns raised
by the EU Code of Conduct Group on Business Taxation that
Guernsey's corporate tax system could facilitate offshore
structures aimed at attracting profits which do not reflect real
economic substance.
The detailed legislation for Guernsey's substance
requirements is contained in The Income Tax (Substance
Requirements) (Implementation) Regulations, 2018, as amended (the
Regulations), and guidance on the key aspects of the economic
substance requirements was updated on 21 December 2018.
On 12 March 2019, the EU Council confirmed that Guernsey had met
its commitment to introduce economic substance requirements and
therefore removed Guernsey from the list of jurisdictions that had
committed to make certain changes, and did not place Guernsey on
the "blacklist" of non-cooperative
