05/06/2026
Substance is increasingly becoming a central consideration in both tax and regulatory assessments.
In this video, Govind Doongoor, Team Leader at GWMS, explains why substance extends far beyond legal structuring and why operational reality matters.
Key considerations include:
• where management and control are exercised
• how tax residency is determined
• whether Core Income Generating Activities (CIGA) are performed appropriately
• whether operational presence supports the activities conducted
• how substance impacts both regulatory positioning and tax certainty
As international standards continue to evolve, businesses are expected to demonstrate that their structures reflect genuine operational activity rather than theoretical positioning.
Watch the video to learn more about the role substance plays in building sustainable and compliant international structures.
Contact our team to discuss your structuring, licensing and compliance requirements.
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GWMS provides structuring, licensing and compliance services only.
We do not provide funding or source investors.