Economic substance: what actually triggers a filing

Substance rules catch more companies than owners expect, because the tests are based on activity rather than size or profit.

A dormant holding company with no income can still owe a notification. Where you are in scope, you must show that core income-generating activity happens in the jurisdiction and that decisions are genuinely taken there.

There are usually two obligations: a notification, and — if in scope — a full substance report. Missing the notification alone carries penalties in most jurisdictions.