A moveable feast—economic substance and holding entities
Abstract The economic substance requirements that the European Union insisted that a number of international financial centres introduce may be the most complex and far-reaching of international initiatives to impact on those jurisdictions in recent years. The requirements extend beyond due diligence, reporting and exchange of information to potentially impact on the way in which entities resource and carry on business in or from those jurisdictions. However, not all sectors of international business are impacted in the same way or to the same extent. This article considers certain aspects of the economic substance requirements relevant to private client structures, with a particular focus on the impact on holding entities. The treatment of holding entities under economic substance legislation in a number of C.2.2 jurisdictions may not be settled and this article explores how it may evolve.