Economic Substance Register

Five regimes, one book — Jersey, Guernsey, Isle of Man, BVI and Cayman

Meridian Fiduciary Limited (illustrative) · prepared 13 August 2026 · statutory position as at 13 August 2026

ES-OFFSHORE-2026 · 14 rules · rev 7c41ab · from an export of 31 entities

This is a reading of 31 entities supplied by Meridian Fiduciary Limited (illustrative) against the economic substance regimes of five jurisdictions. It states, for each entity, whether it is in scope, which relevant activity it carries on, which test applies, what is due when, and what remains unanswered. It does not interpret any constitutional document and it is not legal advice.

1 The population

31Entities supplied

31Evaluated

26Determined

3Not determinable

2Referred to counsel

31	Entities supplied in the export
26	Determined
18	A step falls due
8	No step falls due — no relevant activity, or outside the regime
3	Not determinable on the facts supplied
2	Referred to counsel
31	Reconciles to the population supplied

Nothing was assumed. Where a fact was absent the entity is reported as undetermined and the missing fact is named, which is why section 4 exists and is short.

2 Substance register

One line per entity against the client’s own reference. This sample shows fourteen of the 31 lines.

Ref	Place	Status	Relevant activity	Test	Due	Open item	Counsel
MF-0007	Jersey	Step falls due	Holding company business	Reduced	ES return with the company tax return, 2026-11-30	—	—
MF-0011	Jersey	Step falls due	Fund management business	Full	ES return with the company tax return, 2026-11-30	—	—
MF-0014	Guernsey	Step falls due	Finance and leasing business	Full	With the annual tax return — date from the client tax calendar	Return date to confirm	—
MF-0019	Guernsey	Step falls due	Holding company business	Reduced	With the annual tax return — date from the client tax calendar	Return date to confirm	—
MF-0023	Isle of Man	Step falls due	Distribution and service centre business	Full	With the annual income tax return — date from the client tax calendar	Return date to confirm	—
MF-0026	Isle of Man	No step	None in the period	—	—	—	—
MF-0031	BVI	Step falls due	Holding business	Reduced	2026-12-30, six months after the period ended 2026-06-30	—	—
MF-0033	BVI	Step falls due	Intellectual property business	Enhanced	2026-12-30	Location of the CIGA, and the evidence relied on to displace the presumption	Yes
MF-0038	Cayman	Step falls due	Fund management business	Full	Notification 2027-03-31; ES return 2026-12-31	—	—
MF-0041	Cayman	No step	Investment fund	—	—	—	—
MF-0044	Cayman	Step falls due	Holding company business	Reduced	ES return 2026-12-31	—	—
MF-0047	Jersey	Undetermined	Undetermined	—	—	Certificate of tax residence, or the foreign taxpayer reference relied on	—
MF-0052	BVI	Step falls due	Shipping business	Full	2026-12-30	—	—
MF-0055	Guernsey	Counsel	Headquarters business, in question	—	—	The service agreements and the charging basis	Yes

3 Steps in date order

Date	Place	Step	Count
2026-11-30	Jersey	ES return filed with the company tax return	4 entities
2026-12-30	BVI	ES report through BOSS(ES), filed by the registered agent	5 entities
2026-12-31	Cayman	ES return to the Tax Information Authority	4 entities
2027-03-31	Cayman	Economic substance notification through the General Registry	6 entities
Per entity	Guernsey and Isle of Man	Reporting rides on the annual tax return; the date is taken from the client tax calendar	9 entities

Guernsey and the Isle of Man carry no invented date. Reporting in both rides on the entity’s annual tax return, and that date turns on the entity’s own filing position. The requirement is stated and the date is taken from the client’s tax calendar. A date produced by this process would look identical to one taken from the statute, which is the reason for the distinction.

4 Exceptions

The entities that cannot be settled on the facts supplied, each with the specific fact required.

Ref	Place	Why it is open	Fact required
MF-0047	Jersey	Residence outside Jersey is claimed.	A certificate of tax residence, or the foreign taxpayer reference relied on.
MF-0061	Isle of Man	The activity description does not resolve to a relevant sector.	A description of what the entity did in the period, at the level of the income it earned.
MF-0068	Cayman	Two financial year ends appear in the export.	The financial year end the entity actually adopted.

5 File records

One record per entity, written to be placed on the file. Each names the facts it was decided on, the provision it rests on, and the version of the rules that produced it.

This sample shows four of the 31 records. A delivered reading carries one for every entity in the population.

MF-0007

Result: Reduced substance test applies. ES return due with the company tax return.
Why: A Jersey tax resident company whose primary function is the acquisition and holding of shares, carrying on no commercial activity in the period. Holding company business is a relevant activity under Art. 3(1).
Action: Confirm the statutory filing obligations are met.
Confirm adequate people and premises in Jersey for holding and managing the participations.
File the ES return with the company tax return.
Deadline: ES return with the company tax return: 2026-11-30
Open item: —
Counsel: No step here requires legal advice.
Source: Taxation (Companies – Economic Substance) (Jersey) Law 2019, L.3/2019 — Art. 3(1), Art. 5(2), Art. 6
Assessed: ES-OFFSHORE-2026 · 14 rules · rev 7c41ab
statutory position as at 13 August 2026

MF-0033

Result: Enhanced test applies, and the statutory presumption operates against the entity until displaced.
Why: A BVI company holding intellectual property acquired from a connected person and licensed to connected persons outside the BVI, with no CIGA evidenced in the territory. That is the high-risk profile the Act singles out.
Action: Assemble the evidence relied on to displace the presumption.
Take advice on whether that evidence meets the standard.
Report through the registered agent.
Deadline: ES report: 2026-12-30, six months after the period ended 2026-06-30
Open item: Location of the CIGA, and the evidence relied on to displace the presumption.
Counsel: Legal advice required before the position is settled. The sufficiency of evidence against a statutory presumption is a matter of construction.
Source: Economic Substance (Companies and Limited Partnerships) Act, 2018, as amended
Assessed: ES-OFFSHORE-2026 · 14 rules · rev 7c41ab
statutory position as at 13 August 2026

MF-0041

Result: Outside the regime. No substance test and no return.
Why: A Cayman entity that is an investment fund. An investment fund falls outside the definition of a relevant entity, so the substance requirements do not reach it.
Action: Record the basis of exclusion on the file.
File the annual economic substance notification, which is required of every entity.
Deadline: Notification: 2027-03-31
Open item: —
Counsel: No step here requires legal advice.
Source: International Tax Co-operation (Economic Substance) Act (2024 Revision)
Assessed: ES-OFFSHORE-2026 · 14 rules · rev 7c41ab
statutory position as at 13 August 2026

MF-0047

Result: Undetermined. No position is stated.
Why: The export records the entity as resident outside Jersey. If that is correct the Law does not reach it. The export carries no evidence of the claim, and residence was not assumed in either direction.
Action: Obtain the certificate of tax residence, or the foreign taxpayer reference relied on.
Re-run the assessment on the fact.
Deadline: —
Open item: Certificate of tax residence, or the foreign taxpayer reference relied on.
Counsel: Not reached. The question is one of fact, and the fact is missing.
Source: Taxation (Companies – Economic Substance) (Jersey) Law 2019, L.3/2019 — Art. 2, residence
Assessed: ES-OFFSHORE-2026 · 14 rules · rev 7c41ab
statutory position as at 13 August 2026

Basis. Every result above was produced by applying the rules in the package named in the header to the facts supplied by Meridian Fiduciary Limited (illustrative), and by nothing else. The same facts and the same package reproduce the same register. Where a fact was not supplied, no value was assumed and the entity is reported as undetermined.

Scope. The provisions evaluated are the economic substance requirements of:

Jersey — Taxation (Companies – Economic Substance) (Jersey) Law 2019, L.3/2019
Guernsey — The Income Tax (Substance Requirements) (Implementation) Regulations, 2018, Guernsey SI 2018 No. 90
Isle of Man — Income Tax Act 1970, Part 6A ss. 80B–80N, inserted by SD 2018/0263
BVI — Economic Substance (Companies and Limited Partnerships) Act, 2018, as amended
Cayman — International Tax Co-operation (Economic Substance) Act (2024 Revision)

Guidance issued by the tax authorities is read alongside the Acts and is not encoded as a rule. Sector regulation, tax residence determinations and the adequacy of any particular level of people, premises or expenditure are outside this register.

Terms. This document is provided for evaluation. The rule package named above, its structure, its applicability and exclusion logic and the form of this report are proprietary to New Way Capital Advisory. Publication grants no licence to reproduce it, adapt it, or derive a competing work from it, and no part may be reproduced without written permission. © 2026 New Way Capital Advisory, Geneva.

New Way Capital Advisory is not a law firm and does not practise law in any jurisdiction. This document identifies and applies published legislative provisions for operational purposes. It is not legal or tax advice, it is not an opinion on any entity, and the entities named are illustrative. Anyone acting on a matter described here should take advice qualified in the jurisdiction concerned.

ES-OFFSHORE-2026 · 14 rules · rev 7c41ab · statutory position as at 13 August 2026 · nwc-advisory.com