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Update on Economic Substance Rules for Guernsey Fund Managers

The Income Tax (Substance Requirements) (Implementation) Regulations 2018, as amended, came into effect on 1 January 2019 and apply to accounting periods commencing on or after that date. The new economic substance requirements apply to certain Guernsey tax-resident companies and have been passed in order to comply with the EU Code of Conduct Group on Business Taxation for the purpose of demonstrating that the profits generated by Guernsey companies which carry on certain specified geographically mobile activities, including, in particular, for the purpose of this article, fund management business, are commensurate with their economic activities and substantial economic presence in Guernsey

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