Harneys BVI Legal Update - S.O.S. Substance on Substance

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Substance on Substance

Harneys launches its S.O.S. series, delivering hot takes on critical topics around the Economic Substance legislation.

Each bulletin will give the very latest updates on this ever-changing environment, with an aim to provide consistency and certainty for our audience.

First up, Phil Graham and Josh Mangeot discuss the immediate implications of the presentation Neil Smith, Director of International Business delivered to the BVI private sector on Wednesday 10 July.

Click on the image below to listen.

Subtance on Substance: Episode One

Key takeaways:

  • An update on the timing of the release of the Code and Guidance Notes

  • A steer from the ITA on what they will be expecting all BVI entities to do

  • Clarification around Tax Residence

  • The ITA’s view on the Harneys Economic Substance Classification Solution


Learn more about Substance on Substance.

Key contacts

Philip Graham
Partner • British Virgin Islands
+1 284 852 2551

Joshua Mangeot
Senior Associate • British Virgin Islands
+1 284 852 4387


Economic substance in the BVI: a guide for directors and operators of BVI companies and limited partnerships

The Economic Substance (Companies and Limited Partnerships) Act, 2018 was introduced in the BVI, effective 1 January 2019, to address the concerns of the EU Code of Conduct Group and the OECD Forum on Harmful Tax Practices regarding economic substance.

Learn more

Economic substance – Draft BVI Code published

On 23 April 2019, the British Virgin Islands International Tax Authority (ITA) published a draft Economic Substance Code (the Code). The Code is supplementary to the Economic Substance (Companies and Limited Partnerships) Act, 2018 (ESA) and contains rules on how the economic substance requirements may be met and guidance on the interpretation of the legislation and the manner in which the ITA will carry out its obligations.

Learn more
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