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ARTICLE · 26 MARCH 1999

Taxation In Guernsey - Double Taxation Agreements

GuernseyStrategy

Guernsey has concluded double taxation agreements with the UK and with Jersey. The agreements are based on an old style treaty which do not reflect the provisions contained in the OECD model. The main provisions of the UK and Jersey agreements are as follows:

  • A resident of one, but not both territories, is exempt from tax on industrial and commercial profits arising in the other territory except to the extent that they are attributable to a permanent establishment in the other territory.
  • Notwithstanding the above, profits which a resident of one of the territories derives from operating ships or aircraft are exempt from tax in the other territory.
  • An individual who is resident in one but not both of the territories is exempt from tax in the other territory in respect of personal, including professional, services performed within the other territory provided that the services concerned are performed for and on behalf of a person resident in his own territory and that the

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