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Interpretation of 1952 double taxation agreement

​​Utilising the mutual agreement provisions contained in the 1952 double taxation agreement, Jersey and the UK have agreed that paragraph 2(1)(f) of that agreement contains a residence tie-breaker test for companies which are regarded as resident in both jurisdictions under their relevant domestic tax rules.

Where the tie-breaker test applies, the company is treated as resident in whichever jurisdiction its business is managed and controlled. This means that it is only required to pay tax on most types of income in either Jersey or the UK, not in both places.

This agreement better reflects the originally intended meaning of paragraph 2(1)(f). A company potentially impacted by this decision should contact the Taxes Office, their tax adviser or HMRC. 

Any claim for relief under the double taxation agreement will be subject to the normal time limits applicable under Jersey and UK domestic law.

If you have any queries about this announcement, contact the Taxes Office or HMRC.

Email the Taxes Office

Email HMRC

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