Affected companies should review outsourcing arrangements in respect of Guernsey tax-resident companies that fall within the scope of the new law, and whether the third-party service provider agreements in place meet the tests set out.
De-Risking Governments Around…
It is anticipated that many structures will be compliant with the new requirements already – consideration should be given to whether amendments and updates are required to any policies and procedures as a result of the new law.
IP income-generating companies (tax resident companies with income from intellectual property) will be subject to enhanced requirements, which will be the subject of a separate brie ng in due course.
Further detailed guidance is expected on the precise definition of activities to fall within the scope of the proposed regulations, and the definition of adequacy in respect of employees, expenditure and premises under the ‘Core Income Generating Activities’ test.