The Income Tax (Substance Requirements) (Implementation)
Regulations, 2018 as amended, came into effect on 1 January 2019
and apply for accounting periods commencing on or after that
date. The new economic substance requirements (the Substance
Requirements) apply to certain Guernsey tax-resident companies and
have been passed in order to comply with the requirements of the EU
Code of Conduct Group on Business Taxation for the purpose of
demonstrating that the profits generated by Guernsey companies
which carry on certain specified geographically mobile activities
including, in particular, for the purpose of this briefing, fund
management business, are commensurate with their economic
activities and substantial economic presence in Guernsey.
