Introduction
For many Guernsey tax-resident companies, the onset of the COVID-19 pandemic created difficulties in complying with economic substance requirements.
Guernsey tax-resident companies carrying out certain relevant activities must comply with the substance requirements set out in the Income Tax (Substance Requirements) Implementation Regulations 2018 (as amended) (the regulations). In particular, these include requirements that a company's activities be "directed and managed" from Guernsey, and that certain "core income-generating activities" (CIGAs) be carried out in Guernsey.
Difficulties which such companies have encountered over the past year have included the fact that:
directors and other decision makers who might normally travel to Guernsey to attend board or other meetings in person could not do so because of travel restrictions; and