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Amending Protocol to Tax Treaty between Guernsey and Ireland in Force

20 January 2023

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Treaty Development

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Guernsey-Ireland

According to an update from Irish Revenue, the amending protocol to the 2009 income tax treaty between Guernsey and Ireland entered into force on 19 December 2022. The protocol, signed 8 December 2021, 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);...