Crown dependencies tax treaty amendments

At Budget 2016, the government announced its intention to include legislation in Finance Bill 2016 at report stage to introduce new rules for taxing companies’ trading profits derived from land in the UK, regardless of where a company is resident and whether or not it has a UK permanent establishment. It was announced that changes had been agreed to the double taxation agreements with Guernsey, Jersey and the Isle of Man to preserve the UK’s taxing rights over land, to have effect from 16 March 2016.

These changes have now been published in the:

·       draft Double Taxation Relief (Guernsey) Order 2016;

·       draft Double Taxation Relief (Isle of Man) Order 2016; and

·       draft Double Taxation Relief (Jersey) Order 2016.

The schedule to each of these draft orders contains an exchange of letters amending the existing double taxation arrangements between the UK and, respectively, Guernsey, the Isle of Man and Jersey.