Economic substance update: COVID-19 concessions, self-managed funds and partnerships
Introduction For many Guernsey tax-resident companies, the onset of the COVID-19 pandemic created difficulties in complying with economic substance requirements. Guernsey tax-resident companies carrying out certain relevant activities must comply with the substance requirements set out in the Income Tax (Substance Requirements) Implementation Regulations 2018 (as amended) (the regulations). In particular, these include requirements that a company's activities be "directed and managed" from Guernsey, and that certain "core income-generating activities" (CIGAs) be carried out in Guernsey. Diffi...