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Amending Protocol to Tax Treaty between Guernsey and Ireland

10 January 2022

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Treaty Development

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Guernsey-Ireland

The amending protocol to the 2009 income tax treaty between Guernsey and Ireland was signed on 8 December 2021. The protocol is the first to amend the treaty and includes the following changes: The preamble is replaced in line with OECD BEPS standards; Article 9 (Mutual Agreement Procedure) is amended to provide that a person may present a case to the competent authority of either Contracting State (under the original treaty, may only present to the competent authority of the State of which the person is a resident); Article 9A (Entitlement to Benefits) is added, providing that a benefit under...