Jurisdiction(s):
United Kingdom

Key definition

OECD definition

What does OECD mean? In legal practice, “OECD” refers to the Organisation for Economic Co‑operation and Development, an intergovernmental body of 38 member countries (including the UK and Ireland) whose economic research, standards and policy recommendations often shape domestic law, treaty practice and compliance. The term is descriptive rather than a defined legal term; however, UK and Irish legislation, regulations and treaties frequently incorporate or refer to OECD instruments. Key touchpoints include: - Tax: the OECD Model Tax Convention, OECD Transfer Pricing Guidelines (used by HMRC and Irish Revenue as interpretative guidance), the BEPS project and Pillar Two/GloBE rules implemented in both jurisdictions. -...

Economic substance regimes in Jersey, Guernsey, Isle of Man, Bermuda, Cayman Islands and British Virgin Islands: comparative overview of scope, CIGA, residence, reporting and sanctions

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Practice notes

Jersey, Guernsey and the Isle of Man, along with the Overseas Territories of Bermuda, the Cayman Islands and the British Virgin Islands, have enacted new economic substance laws for companies and other entities operating in their jurisdictions. These Rules apply to accounting periods beginning on or after 1 January 2019.

Background

In 2016, the EU Council pledged co-ordinated action against tax fraud, evasion and avoidance, and approved conclusions setting out the criteria and process for creating the EU list of non-co-operative jurisdictions for tax purposes. Accordingly, the EU Code of Conduct Group (Business Taxation) (COCG) was asked by the Council to carry out a review under which jurisdictions, including the Crown Dependencies, were evaluated against three benchmarks:

tax transparency
fair taxation
adherence to anti-base erosion and profit shifting (BEPS) measures

In December 2017, the COCG published a list of non-co-operative tax jurisdictions. To avoid potential blacklisting, most countries committed to reform the elements of their tax systems flagged as harmful by the COCG, following its timetable and guidance...

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Web page updated on 21/05/2026

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