Groups will need to review their existing arrangements and consider appropriate jurisdictions for new investments, write Emily Osborne and Hilary Barclay (Stephenson Harwood).
The new world
The new economic substance rules introduced in the Crown Dependencies and certain Overseas Territories (CDOT) focus on the tax residence and activities of corporate entities. If a company is tax resident in the relevant territory and carries on relevant income-generating activities it will be subject to the new rules. Failure to comply can result in financial penalties and potentially the company being struck off. Full draft guidance was published in the various territories at the end of April and some practical implications for multinational groups are starting to become apparent.
Corporate tax residence
Until recently multinational groups and investors looking for a tax neutral flexible...
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Groups will need to review their existing arrangements and consider appropriate jurisdictions for new investments, write Emily Osborne and Hilary Barclay (Stephenson Harwood).
The new world
The new economic substance rules introduced in the Crown Dependencies and certain Overseas Territories (CDOT) focus on the tax residence and activities of corporate entities. If a company is tax resident in the relevant territory and carries on relevant income-generating activities it will be subject to the new rules. Failure to comply can result in financial penalties and potentially the company being struck off. Full draft guidance was published in the various territories at the end of April and some practical implications for multinational groups are starting to become apparent.
Corporate tax residence
Until recently multinational groups and investors looking for a tax neutral flexible...
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:
