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HMRC internal manual

Double Taxation Relief Manual

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

An individual who is a resident of one country and also resident in the other country is not a resident of either country for the purposes of the agreement (see INTM154020). A company is a resident of the country in which it is taxed as a resident either because it is managed and controlled in that country or because it is incorporated there. Where a company which is incorporated in the United Kingdom, but managed and controlled in Guernsey, claims to be a resident of Guernsey, no claim should be admitted and the case should be referred to Business International.

Under the further agreement mentioned in DT8600, any person who is entitled to special Guernsey tax benefits under either

  1. The Income Tax (Exempt Bodies) (Guernsey) Ordinances 1989 and 1992


  1. The Income Tax (International Bodies) (Guernsey) Law 1993

is not entitled to relief or exemption from United Kingdom tax computed by reference to any income or profits arising on or after 3 January 1995, unless that person is assessed to tax thereon in Guernsey under those provisions at a rate which is not less than the standard rate of Guernsey income tax (currently 20 per cent).