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Jersey-Seychelles

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Tax Treaty between Jersey and Seychelles has Entered into Force

The income tax treaty between Jersey and Seychelles entered into force on 5 January 2017. The treaty, signed 28 July 2015, is the first of its kind between the two jurisdictions.

Taxes Covered

The treaty covers Jersey income tax and Seychelles business tax, income and non-monetary benefits tax, and petroleum income tax.

Service PE

The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services through employees or other engaged personnel if the activities continue for the same or connected project within a Contracting Party for a period or periods aggregating more than 183 days within any 12-month period.

Withholding Tax Rates

  • Dividends - 0%
  • Interest - 0%
  • Royalties - 0%

Capital Gains

The following capital gains derived by a resident of one Contracting Party may be taxed by the other Party:

  • Gains from the alienation of immovable property situated in the other Party;
  • Gains from the alienation of movable property forming part of the business property of a permanent establishment in the other Party; and
  • Gains from the alienation of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in the other Party

Gains from the alienation of other property by a resident of a Contracting Party may only be taxed by that Party.

Note - The text of the treaty as published by the Jersey government includes a duplication of the standard provision regarding the taxing rights of gains from the alienation ships and aircraft operated in international traffic, and does not include the standard provision regarding the taxing rights of gains from the alienation of movable property of a PE. This is assumed to be in error.

Double Taxation Relief

Both jurisdictions apply the credit method for the elimination of double taxation.

Effective Date

The treaty applies from 1 January 2018.

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