The Economic Substance legislation is contained in Part 6A Income Tax Act 1970.
The Income Tax Act 1970 is available online at www.legislation.gov.im
Part 6A Income Tax Act 1970 was introduced by a temporary taxation order but the provisions have now been incorporated into the primary legislation.
A change was approved by Tynwald on 16 June 2021 which extends the scope of substance to partnerships and Limited Liability Companies.
The most recent guidance in relation to Economic Substance can be found here:
The joint 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.
Guidance in relation to Economic Substance is published by the Isle of Man, jointly with Guernsey and Jersey.
- The first piece of guidance to be issued was the Key Aspects document published on 5 November 2018, and this was updated on 20 December 2018.
- The second and more detailed piece of guidance was version 1 of the ‘joint guidance’, which was published on 26 April 2019, and then replaced by version 2 on 22 November 2019.
- The third guidance was also jointly issued and provides additional guidance on the scope and application of the economic substance legislation regarding partnerships. This guidance was issued on 21 December 2021.
Links to all of the published guidance, including historic versions can be accessed via the links in the ‘published guidance’ section below.
For information on the Code of Conduct for Business Taxation and EU Listing Process from 2016 please visit the EU Listing pages.
If you would like to be added to our mailing list in order to receive updates when new Economic Substance documentation or guidance is published, please supply your details on the Mail List Contact Form.
Economic Substance – Document Archive
Legislation (earliest publication listed first)
- Draft Isle of Man Legislation—Income Tax (Substance Requirements) Order 2018
- Approved Isle of Man Legislation – Income Tax (Substance Requirements) Order 2018
- Approved Isle of Man Legislation - Income Tax (Substance Requirements) (Amendment) Order 2019
- Approved Isle of Man Legislation - Income Tax (Substance Requirements) (Amendment) Order 2020
- Approved Isle of Man Legislation - Income Tax (Substance Requirements) Order 2021
Published Guidance (earliest publication listed first)
- Key Aspects in relation to proposed economic substance requirements - Issued jointly by Guernsey, Isle of Man and Jersey - 5 November 2018
- Substance Flowchart (part of the Key Aspects document)
- 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
- Updated Economic Substance Guidance - Joint Guernsey Isle of Man and Jersey - 22 November 2019
- Economic Substance – Joint Guidance on the Application of Rule to Partnerships – 21 December 2021