On 16 March 2015, Seychelles published in its Official Gazette the statutory instrument ratifying the pending income tax treaty with Guernsey. The treaty, signed 27 January 2014, is the first of its kind between the two jurisdictions.
The treaty covers Guernsey income tax, and Seychelles business tax, income and non-monetary benefits tax, and petroleum income tax.
The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise of one Contracting Party furnishes services in the other Contracting Party through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 183 days in any 12 month period.
Both jurisdictions apply the credit method for the elimination of double taxation.
The treaty will enter into force 30 days after the ratification instruments are exchanged, and will apply from 1 January of the year following its entry into force.
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