It is anticipated that many structures will be compliant with the new requirements already – consideration should be given to whether amendments and updates are required to any policies and procedures as a result of the new law.
IP income-generating companies (tax resident companies with income from intellectual property) will be subject to enhanced requirements, which will be the subject of a separate brie ng in due course.
Further detailed guidance is expected on the precise definition of activities to fall within the scope of the proposed regulations, and the definition of adequacy in respect of employees, expenditure and premises under the ‘Core Income Generating Activities’ test.
Tim Clipstone
Group Partner
