Core Income Generating Activities (CIGA)

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*Board minutes should at a minimum, evidence key strategic decisions being made in the meeting held at the appropriate location. If the board of directors does not, in practice, make the key decisions, tax authorities will look to understand who does, and where.


t all CIGAs that are listed in the relevant Islands’ Regulations need to be carried out, but those that are, must comply with substance requirements.
Certain back office roles such as IT and accounting support do not comprise CIGAs.
In general, the substance requirements have been designed to respect outsourcing models, though where CIGAs are outsourced they should still be carried out in the Island and be adequately supervised.
Adequate Physical Presence

Demonstrated by having adequately qualified employees, premises and expenditure on Island.
It is common practice that the physical presence can be demonstrated through outsourcing new zealand mobile database to an Island-based administrator or corporate service provider, though such providers cannot double-count their resources provided.
What Information is Required to be Provided?

As part of the income tax filing process, companies carrying on relevant activities will be required to provide the following information:

business/income types, in order to identify the type of relevant activity;
amount and type of gross income by relevant activity – this will generally be the turnover figure from the financial statements;
amount of operating expenditure by relevant activity – this will generally be the company’s operating expenditure from the financial statements, excluding capital;
details of premises – business address;
number of (qualified) employees, specifying the number of full-time equivalents;
confirmation of the Core Income Generating Activities (CIGA), conducted for each relevant activity;
confirmation of whether any CIGA has been outsourced and if so relevant details;
the financial statements; and
net book value of tangible assets.