The Income Tax (Substance Requirements) (Implementation)
Regulations, 2018 came into force on 1 January 2019, requiring all
Guernsey tax-resident companies to confirm, for tax periods
commencing on 1 January 2019 or later, whether they are in scope of
the substance requirements and, if so, how they meet such
requirements.
The substance requirements apply to Guernsey tax-resident
companies that carry on certain specified geographically mobile
activities, including fund management business. They have been
implemented in order to comply with the requirements of the EU Code
of Conduct Group for the purpose of demonstrating that the profits
generated by such companies are commensurate with their economic
activities and presence in Guernsey. Guernsey was put on the EU
whitelist on 12 March.
