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Corporate residence and the economic substance requirements

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The EU’s Code of Conduct Group (COCG) on Business Taxation has been examining jurisdictions to see how they stand up against the EU’s view on tax transparency, fair taxation and compliance. In 2017, a new requirement was introduced, whereby a jurisdiction must introduce economic substance requirements for companies tax resident there in order to avoid being classified as non-cooperative and blacklisted. Companies resident in jurisdictions with economic substance requirements will be subject to the new rules for accounting periods beginning on or after 1 January 2019. We wait to see whether the rules are imposed with a light touch for the first year.
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