
Economic Substance
SCHEDULE 1:
Definition of Core Income Generating Activities in the Economic Substance (Companies and Limited Partnerships Act, 2018).
“Core Income Generating Activities” includes, in respect of banking business:
(a) raising funds, managing risk including credit, currency and interest risk;
(b) taking hedging positions;
(c) providing loans, credit or other financial services to customers;
(d) managing regulatory capital;
(e) preparing regulatory reports and returns.
“Core Income Generating Activities” includes, in respect of distribution and service centre business:
(a) transporting and storing goods;
(b) managing stocks;
(c) taking orders;
(d) providing consulting or other administrative services.
“Core Income Generating Activities” includes, in respect of insurance business:
(a) predicting and calculating risk;
(b) insuring or re-insuring against risk;
(c) providing insurance business services to clients.
“Core Income Generating Activities” includes, in respect of fund management business:
(a) taking decisions on the holding and selling of investments;
(b) calculating risks and reserves;
(c) taking decisions on currency or interest fluctuations and hedging positions;
(d) preparing relevant regulatory or other reports for government authorities and investors.
“Core Income Generating Activities” includes, in respect of finance or leasing business:
(a) agreeing funding terms;
(b) identifying and acquiring assets to be leased (in the case of leasing);
(c) setting the terms and duration of any financing or leasing;
(d) monitoring and revising any agreements;
(e) managing any risks;
“Core Income Generating Activities” includes, in respect of headquarters business:
(a) taking relevant management decisions;
(b) incurring expenditures on behalf of affiliates;
(c) co-ordinating group activities.
“Core Income Generating Activities” includes, in respect of shipping business:
(a) managing the crew (including hiring, paying and overseeing crewmembers);
(b) hauling and maintaining ships;
(c) overseeing and tracking deliveries;
(d) determining what goods to order and when to deliver them;
(e) organising and overseeing voyages.
“Core Income Generating Activities” includes, in respect of intellectual property business:
(a) where the business concerns intellectual property assets such as patents, research and
development;
(b) where the business concerns non-trade intangible assets such as brand, trademark and customer data, marketing, branding and distribution.
