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HMRC internal manual

International Manual

HM Revenue & Customs
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Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - Scope of the UK/Guernsey Double Taxation Arrangement

1952 arrangement

The 1952 arrangement has very restricted scope, as it contains no articles dealing with:

  • dividends
  • interest
  • royalties
  • pensions (but see below wef 6 April 2010)
  • other income

No relief can therefore be available under the arrangement in respect of these categories of income.

But relief may be available to a Guernsey ‘enterprise’ under the ‘Industrial or commercial profits’ INTM352725

Effects of the amended arrangement-wef 6 April 2010

The amended arrangement now allows exemption from UK tax on:

  • pensions (including state pension)
  • annuities
  • trivial commutation lump sums

However, no relief is available in respect of the above if the individual has “dual resident” status.

If in any doubt or difficulty regarding “dual residence” please submit case to PT International Advisory (DT), Room 240 St John’s House, Merton Road, Liverpool L75 1BB.