This has led to a review of offshore structures
Posted: Thu Feb 20, 2025 5:01 am
Social and environmental concerns are high on consumers' agendas, especially when looking to invest, as is a reputational awareness of where an individual or family's assets are managed.
Clients and their families want to be more mobile and flexible and need properly structured advice.
With the constant threat of further lockdowns, individuals and families need to consider where they want to live. We are seeing an increase within the Dikkart Group in customers considering moving to jurisdictions deemed ‘safer’ as a result of the increase in the number of private residences.
What has been the impact of the 'Economic Substance Requirements' (ESR) legislation iran mobile database which has now been introduced in around 140+ international jurisdictions?
The ESR is an extension of the historic ‘mind and control’ requirements and BEPS legislation, which was introduced to ensure that structures meet the appropriate tax residency test. Where jurisdictions already have a good track record of tax compliance and harmonisation the ESR effectively puts into law what was best practice for these jurisdictions.
In particular by clients and their advisors, with questions being asked about the purpose of the structure and whether this is still relevant under the new law. Decisions are then made whether to amend the structures, relocate them onshore or to a more suitable jurisdiction, or simply close them.
Jurisdictions with a less favorable track record of meeting international standards are now facing an uphill battle to meet the ESR legal requirements, which has resulted in banking and credit institutions reviewing all their arrangements with structures located in these jurisdictions.
We are pleased to report that the EU Code of Conduct Group approved Guernsey’s substance regime in March 2019. This was followed by further support in July 2019 by the OECD Forum on Harmful Tax Practices, which concluded that Guernsey’s domestic legal framework was consistent with agreed standards and therefore “not harmful”.
Clients and their families want to be more mobile and flexible and need properly structured advice.
With the constant threat of further lockdowns, individuals and families need to consider where they want to live. We are seeing an increase within the Dikkart Group in customers considering moving to jurisdictions deemed ‘safer’ as a result of the increase in the number of private residences.
What has been the impact of the 'Economic Substance Requirements' (ESR) legislation iran mobile database which has now been introduced in around 140+ international jurisdictions?
The ESR is an extension of the historic ‘mind and control’ requirements and BEPS legislation, which was introduced to ensure that structures meet the appropriate tax residency test. Where jurisdictions already have a good track record of tax compliance and harmonisation the ESR effectively puts into law what was best practice for these jurisdictions.
In particular by clients and their advisors, with questions being asked about the purpose of the structure and whether this is still relevant under the new law. Decisions are then made whether to amend the structures, relocate them onshore or to a more suitable jurisdiction, or simply close them.
Jurisdictions with a less favorable track record of meeting international standards are now facing an uphill battle to meet the ESR legal requirements, which has resulted in banking and credit institutions reviewing all their arrangements with structures located in these jurisdictions.
We are pleased to report that the EU Code of Conduct Group approved Guernsey’s substance regime in March 2019. This was followed by further support in July 2019 by the OECD Forum on Harmful Tax Practices, which concluded that Guernsey’s domestic legal framework was consistent with agreed standards and therefore “not harmful”.