Economic substance.

Meeting substance requirements in the jurisdictions where you operate, with structures that are real, defensible and properly maintained.

What it is

Real, and demonstrably so.

A structure is only as good as the substance behind it. Jurisdictions increasingly require that an entity has real activity, people and management where it claims to operate — and the benefit of a structure can be lost where that substance is absent or cannot be shown. Substance is no longer a formality; it is a condition.

We establish what substance each relevant jurisdiction requires, build it into the structure from the outset, and keep it properly maintained — so the structure is real, defensible and able to demonstrate it.

How we advise

Substance requirements

Establishing what each jurisdiction requires of an entity that operates there.

Building it in

Designing structures with the activity, people and management they need.

Maintenance

Keeping substance current, so it holds when it is tested.

Evidence

Holding the records that demonstrate substance on request.

Important information

The basis on which we advise.

This page is general in nature and does not constitute tax, legal or financial advice. Advice is given only under a formal engagement, on the basis of your specific circumstances.

ORA Black advises on the design, selection and coordination of structures; it does not act as trustee, foundation council member or administrator, and does not hold client assets. Fiduciary, formation and administration services are provided by appropriately licensed and regulated providers. Where regulated financial services are required, these are provided through ORA Black’s partnership with NEBA Private Clients, under the authorisation of the entity licensed in the relevant jurisdiction.

Structure, reviewed properly.

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