EXPLANATORY NOTE

(This note is not part of the Order)

The Schedule to the Order contains an Exchange of Letters between the United Kingdom and Guernsey concerning an Arrangement amending the 1952 Arrangement between the two parties for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, which was scheduled to the Double Taxation Relief (Taxes on Income) (Guernsey) Order 1952 (S.I. 1952/1215) and subsequently amended in 1994 and 2009. The Schedule also contains the text of the Arrangement referred to in the Exchange of Letters.

Article 2 provides that it is expedient that the Arrangement should have effect. The Arrangement relates to the avoidance of double taxation and varies the arrangements set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Guernsey) Order 1952.

The Arrangement will enter into force on the date of the later of the notifications of each territory of the completion of its legislative procedures. It will take effect in the United Kingdom—

(a)in respect of income tax, for any year of assessment beginning on or after 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 1st April next following the date on which the Arrangement enters into force.

The Arrangement will take effect in Guernsey in respect of income tax, for any year of assessment beginning on or after 1st January next following the date on which the Arrangement enters into force.

The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.

A Tax Information and Impact Note has not been produced for this Order as it gives effect to a previously announced policy to enact a double taxation agreement.