UK HMRC has published a Memorandum of Understanding (MoU) between the competent authorities of the UK and Guernsey concerning arbitration under article 25 of the 2018 income and capital tax agreement between the two jurisdictions. The MoU was signed on 16 June 2022 and is effective with respect to cases presented on or after the date the tax agreement entered into effect. For Guernsey, the agr…