According to an update from Irish Revenue, the amending protocol to the 2009 income tax treaty between Guernsey and Ireland entered into force on 19 December 2022. The protocol, signed 8 December 2021, is the first to amend the treaty and includes the following changes:
- The preamble is replaced in line with OECD BEPS standards;
- Article 9 (Mutual Agreement Procedure) is amended to provide that a person may present a case to the competent authority of either Contracting State (under the origi…