The income tax treaty between Guernsey and Seychelles entered into force on 12 October 2016. 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 furnishes services in a Contracting Party through employees or other engaged personnel for the same or connected project for a period or periods aggregating more than 183 days within any 12-month period.
The following capital gains derived by a resident of one Contracting State may be taxed by the other State:
Gains from the alienation of other property by a resident of a Contracting State may only be taxed by that State.
Both jurisdictions apply the credit method for the elimination of double taxation.
The treaty applies from 1 January 2017.
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