Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Crown dependencies consult on substance requirements for corporate residence
Jersey Guernsey and Isle of Man each propose to introduce substance requirements for company tax residence. The consultations launched in August were in response to concerns expressed by the EU Code of Conduct Group (Business Taxation) (COGC) about the lack of a need for a business to demonstrate economic substance in order to be tax resident in any of these three jurisdictions. The COGC were concerned that this increases the risk that profits registered in a jurisdiction are not commensurate with economic activities and substantial economic presence.
Substance requirements will be imposed on companies undertaking ‘relevant activities’. It is anticipated that the substances requirements will apply for accounting periods beginning on or after 1 January 2019....
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Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Crown dependencies consult on substance requirements for corporate residence
Jersey Guernsey and Isle of Man each propose to introduce substance requirements for company tax residence. The consultations launched in August were in response to concerns expressed by the EU Code of Conduct Group (Business Taxation) (COGC) about the lack of a need for a business to demonstrate economic substance in order to be tax resident in any of these three jurisdictions. The COGC were concerned that this increases the risk that profits registered in a jurisdiction are not commensurate with economic activities and substantial economic presence.
Substance requirements will be imposed on companies undertaking ‘relevant activities’. It is anticipated that the substances requirements will apply for accounting periods beginning on or after 1 January 2019....
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
