Q&As

What are the UK’s automatic exchange of information obligations with Guernsey?

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Published on LexisPSL on 06/09/2016

The following Tax Q&A provides comprehensive and up to date legal information covering:

  • What are the UK’s automatic exchange of information obligations with Guernsey?
  • What are the UK’s automatic exchange of information obligations with Guernsey?
  • Double Taxation Relief and International Tax Enforcement (Guernsey) Order 2009
  • Tax information exchange agreement
  • The intergovernmental agreement between the UK and Guernsey
  • The future of automatic exchange between the UK and Guernsey

What are the UK’s automatic exchange of information obligations with Guernsey?

What are the UK’s automatic exchange of information obligations with Guernsey?

There are three relevant sources of law on this topic:

  1. Double Taxation Relief and International Tax Enforcement (Guernsey) Order 2009, SI 2009/3011

  2. International Tax Enforcement (Guernsey) Order 2013, SI 2013/3154 and

  3. Intergovernmental agreement (IGA) between the UK and Guernsey

Double Taxation Relief and International Tax Enforcement (Guernsey) Order 2009

As set out in the explanatory notes to SI 2009/3011 (found after the Schedule), the dates of coming into force are published in the London, Edinburgh and Belfast Gazettes. This publication happened on 31 December 2009 (see: London Gazette 31 December 2009) where it states that SI 2009/3011 came into force in respect of capital gains tax, corporation tax, income tax, inheritance tax and VAT on 17 November 2009 (the order is listed four times, ie once in respect of each tax).

The explanatory note goes on to say:

'It will take effect in the United Kingdom—

'(a) in respect of income tax, for any year of assessment beginning on or after the 6th April next following the date on which the Arrangement enters into force; and

'(b) in respect of corporation tax, for any financial year beginning on or after the 1st April next following the date on which the Arrangement enters into force.'

Therefore, given

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