The governments of Guernsey, the Isle of Man, and Jersey are working on proposals for minimum substance requirements that companies tax resident in the respective jurisdictions will need to meet. The need for such requirements is a result of the EU Code of Conduct Group’s concerns that companies tax resident in these jurisdictions having sufficient substance to access the respective corporate tax regimes. The activities that would be required to demonstrate substance requirements include: Banking; Insurance; Fund Management; Finance and leasing; Shipping; Collective Investment Vehicles; Intellectual Property; and Holding companies that generate income from any of these key activities. The...