Economic Substance

Highly relevant to a wide range of corporate entities, including holding companies, intellectual property companies, corporate headquarters, insurers, fund managers, service centres and financial services groups, it is essential to be able to demonstrate compliance with today’s substance requirements designed to protect against harmful tax practices.

Legislation has been introduced in a number of offshore centres designed to guard against what are considered harmful tax practices (Base Erosion and Profit Shifting – BEPS).  Where companies derive income offshore there are specific requirements placed upon them.  Full compliance ensures that significant financial penalties and reputational damage are not incurred.

Full compliance can be demonstrated, however, by deploying the right combination of governance and physical characteristics in corporate design.

The most important early step is to ensure correct classification, with which Highvern is well placed to assist.  Working with your advisors where necessary, we will consider legal status, tax residence and actual offshore activities to identify any potential substance issues and work with you to find rapid, cost-effective solutions.  These may include :

• Registered office
• Provision of directors
• Introduction to independent non-executive directors
• Company secretarial services
• Corporate governance support
• Provision of regulatory support and officers (Compliance Officer, Money Laundering Compliance and Reporting Officers)
• Substance, office space, infrastructure, systems and employees
• Payroll administration for Jersey employees
• Management accounting and reporting
• Settlements, cash and FX management
• Transaction support services
• Reviewing delegations to third parties

We are also open to discussing additional needs as we seek to meet your specific substance requirements.