DT8602 - Double Taxation Relief Manual: Guidance by country: Guernsey: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either territory before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Guernsey is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	0%	10
Dividends on direct investments	0%	10
Conditions for lower rate on dividends on direct investments	N/A	N/A
Property income dividends	15%	10
Interest	See note 1	11
Royalties	See note 2	12
Government pensions	Exempt from tax in the UK unless the individual is ordinarily resident in the UK	18
Other pensions	Taxable only in the UK	17
Arbitration	Yes	25

Note 1: Although the Agreement allows for taxation by the territory in which the interest arises, in accordance with domestic law, there are many exemptions listed in paragraph 3 of Article 11, which make the interest taxable only in the territory of residence of the beneficial owner of the interest, for example the other territory itself, a bank or building society, a pension scheme or an individual.

Note 2: Although the Agreement allows for taxation by the territory in which the royalty arises, in accordance with domestic law, there are many exemptions listed in paragraph 3 of Article 12, which make the royalty taxable only in the territory of residence of the beneficial owner of the royalty, for example where the owner is the other territory itself or an individual.