On 25 June 2014, Guernsey ratified the pending income tax treaty with Seychelles. The treaty was signed 27 January 2014, and 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 provisions 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 countries 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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