Bell Rock glossary

Core Income-Generating Activities

The essential, value-driving activities that an in-scope Cayman entity must conduct in the Islands to satisfy the economic substance test.

CIGA

Economic Substance

International Tax Co-operation (Economic Substance) Act (As Revised)

October 17, 2026

Core Income-Generating Activities (CIGA) are the activities that are of central importance to a relevant entity in generating the income from its relevant activity, and which must be carried on in the Cayman Islands to satisfy the economic substance test. The specific CIGA differ by relevant activity; for example, the CIGA for a fund management business differ from those for a holding company or a financing and leasing business. Identifying the correct CIGA, and evidencing that they are conducted in Cayman with adequate resources, is central to a defensible economic substance position.

Related guidance

Economic Substance Return · Economic Substance Notification

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