Economic Substance

On 26 April 2019 the Crown Dependencies issued more comprehensive guidance on the economic substance requirements to supplement the key aspects document that was issued in December 2018.  This guidance should be read in conjunction with the legislation for each Island and in the Isle of Man is issued under Section 80M of the Income Tax Act 1970.

This guidance is being published jointly by Guernsey, Jersey and the Isle of Man now, to enable industry to engage and provide feedback, however it is to be treated as a work in progress recognising that further technical aspects will develop through further discussions with the European Union Code of Conduct Group on Business Taxation and the Organisation for Economic Co-operation and Development Forum on Harmful Tax Practices.

For information on the Code of Conduct for Business Taxation and EU Listing Process from 2016 please visit the EU Listing pages.

Keeping Updated

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Economic Substance Documents

• Draft Isle of Man Legislation—Income Tax (Substance Requirements) Order 2018
• Key Aspects in relation to proposed economic substance requirements - Issued jointly by Guernsey, Isle of Man and Jersey - 5 November 2018
• Substance Flowchart
• Approved Isle of Man Legislation – Income Tax (Substance Requirements) Order 2018
• OECD BEPS Inclusive Framework substantial activities requirement to "no or only nominal tax" jurisdictions.
• Updated Key Aspects in relation to proposed economic substance requirements - Issued jointly by Guernsey, Isle of Man and Jersey – 20 December 2018
• Economic Substance Guidance Joint Guernsey Isle of Man and Jersey - 26 April 2019