The governments of Guernsey, the Isle of Man and Jersey have
today released version 2.0 of their joint guidance on the economic
substance requirements that apply to certain companies in those
jurisdictions. For further information on those requirements see
our previous notes
here and
here.
The revised guidance builds on version 1.0 of the guidance,
which was published in April 2019, and provides additional guidance
in the following key areas:
Core income generating activities:
- The revised guidance goes further than before by prohibiting a
relevant sector company from undertaking core income generating
activities (CIGA) outside the island in which it
is tax resident. It explains that this does not include
non-income generating activities. It is not clear whether
this prohibition would extend to activities that do generate income
(but not in a relevant sector).