An article from Out-Law on 4 May argues that coronavirus travel restrictions may make it difficult for some companies incorporated in countries with zero or nominal corporate tax rates to comply with the economic substance rules that have been introduced over the last few years. It refers in particular to the economic substance rules which require companies to use a minimum level of local human and technical resources. The rules were introduced to stop companies having only paper operations in a country so they can benefit from low-tax or no-tax regimes.
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