Guernsey issues circular on company’s jurisdiction of residence

On 13 March 2019, the Revenue Service of Guernsey published circular no. 10, providing important information on the process for notifying the Revenue Service of changes to a company’s jurisdiction of residence (Link). With effect from 1 January 2019, a company will be treated as tax resident in Guernsey in a year of charge if it is controlled in Guernsey, or is centrally managed and controlled in Guernsey in that year of charge, or it is incorporated in Guernsey and has not been granted an exemption from tax for that year of charge under any Ordinance made under section 40A of the respective law (Link). A tax resident company will be required to file a company tax return and will be subject to the substance requirements, such as tax transparency, if it carries on geographically mobile financial and other service activities. For further information on the activities, legislation and guidance the Revenue Service in Guernsey created an information webpage (Link).

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