The concept of substance is one of the most difficult to characterise and one of the most relevant on the current scene of international taxation.
On this white paper, we attempt to identify the key elements of the concept of substance, providing some guidelines and identifying the requirements to take into consideration in each of the jurisdictions in which NEWCO operates.
We'll cover, in particular:
- The concept of substance in internationa taxation;
- Basic elements: economic motivation, effective management, effective beneficiary;
- Substance requirements;
- The perspective of the investor's country of origin.