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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Guernsey: Agreement

The agreement (SI 1952/1215) has effect

a) In the United Kingdom for

i) Income Tax from 1951-52,

ii) Corporation Tax from 1 April 1964.

b) In Guernsey from the year of charge beginning 1 January 1951.

A further agreement (SI 1994/3209), amending certain provisions of the 1952 agreement, had effect from 3 January 1995.

A further amending agreement (SI 2009/3011) which introduced provisions on pensions and a mutual agreement procedure and amended certain other provisions of the 1952 agreement had effect in the United Kingdom from 6 April 2010 for income tax purposes and 1 April 2010 for corporation tax purposes. It had effect in Guernsey from 1 January 2010.

Although the 1952 agreement does allow for some exchange of information, the United Kingdom also has a tax information exchange agreement (TIEA) with Guernsey, which entered into force on 27 November 2009 and is effective from the same date.

Details as to what information can be exchanged can be found in the agreement itself. If using the HMRC Intranet, the agreement can be viewed through the “New treaties/protocols in force” link on the sidebar, following the TIEAs link on the subsequent sidebar. On the HMRC web-site, searching for “TIEAs in force” will provide a link to the agreements page.

The text of the Tax Treaty can be found via