Consultation on future Channel Island Fund Management Substance: the Codification of a Sustainable Model

On 6 August 2018, the Governments of Guernsey and Jersey, moving in lock-step with their Isle of Man counterparts, issued substantially identical "high level" Consultation documents which signal the substance requirements corporate fund managers tax resident in the Channel Islands (CIs) will be required to meet from 1 January 2019.

The proposals, now subject to local industry consultation until 31 August 2018, have been designed to reassure the EU's Code of Conduct Group on Business Taxation (the Code Group) that the activities of CI tax resident corporate fund managers (and CI companies undertaking certain other "relevant activities"), which are subject to a zero rate of corporate income tax, are carried on with an appropriate level of local substance. (The other "relevant activities", which are not the subject of this briefing, are: banking, insurance, financing and leasing, headquarters activities, shipping and holding company activities.)