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ARTICLE · 23 NOVEMBER 2018

Guernsey's New Substance Requirements - Application To The Funds Industry

Carey Olsen
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Like other offshore jurisdictions, Guernsey will be implementing legislative economic substance requirements by the end of 2018 to address concerns raised by the EU Code of Conduct Group on Business Taxation...

GuernseyTax
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Like other offshore jurisdictions, Guernsey will be implementing legislative economic substance requirements by the end of 2018 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.

Our previous briefing on the substance requirements as set out in Guernsey's 2019 Budget includes a detailed background on the rules and can be found here.

A draft of the detailed legislation for Guernsey's substance requirements, The Income Tax (Substance Requirements) (Implementation) Regulations, 2018 (the Regulations), was released on 8 November 2018 and guidance on the key aspects of the economic substance requirements was released on 5 November 2018. The States of Guernsey Revenue Service (the Revenue Service) is working with the tax authorities of Jersey and the Isle of Man to produce comprehensive

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