In the tax law context, “substance” can be understood to mean a group or company’s presence in a particular jurisdiction or its connection thereto. Tax authorities around the world have various (and sometimes, diverging but overlapping) parameters for determining whether a particular group or company has “sufficient substance” or “relevant nexus” to their particular jurisdictions. However, there are some commonalities of substance indicators (or if formally mandated, substance requirements) within the E.U.
