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Introduction of substance requirements for certain Guernsey tax resident companies

KPMG Tax breakfast seminar

15 November 2018, 8:00AM - 10:00AM, GMT

Our breakfast seminar focused on the introduction of economic substance requirements for certain Guernsey tax resident companies.

As part of a review of over 90 jurisdictions, the EU Code of Conduct Group (Business Taxation) (“the COCG”) concluded that Guernsey and the other Crown Dependencies were compliant with most of the EU principles of tax good governance, including the general principles of “fair taxation”. However, it did raise concerns regarding the lack of legal substance requirements for doing business in and through the respective jurisdictions.

Guernsey, along with the other Crown Dependencies, made a commitment to address these concerns by the end of December 2018 and they have subsequently worked together with the COCG to develop proposals to meet those commitments.

We understand that draft legislation and guidance notes on the economic substance requirements will be released in early November 2018.

Our breakfast event offered an opportunity to hear from KPMG on how we think the proposed changes may impact local companies. We provided insights on which companies are affected, what such companies need to do to comply with the proposals, the increased reporting required by companies, and finally what happens if everything goes wrong, which could ultimately result in the company being struck off.


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  • 8.00am: Registration and light breakfast
  • 8.30am: Presentation
  • 9.30am: Q&A
  • 10.00am: Close


Tony Mancini, Tax Partner

Paul Beale, Senior Manager


For more information, please contact Joni Free

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