(July 1, 2015)

Based on the overview of Tax Information Exchange Agreements (TIEA) as published on the website of the government of the States of Guernsey, the TIEA that was concluded between Guernsey and Italy entered into force on June 10, 2015.

Based on paragraph 1 of Article 3 of the TIEA the taxes which are the subject of this Agreement are: 

a)     in Italy:

-         the personal income tax;

-         the corporate income tax;

-         the regional tax on productive activities;

-         the value added tax;

-         the inheritance tax;

-         the gift tax;

-         the substitute taxes;

b)     in Guernsey:

-         the income tax;

-         the dwellings profits tax.

Paragraph 2 of Article 3 of the TIEA determines that the Agreement shall also apply to any identical taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes. The Agreement shall also apply to any substantially similar taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes if the Parties through their competent authorities so agree.

Article 5 of the TIEA contains regulations regarding the Exchange of Information upon Request, Article 6 contains regulations regarding the Possibility of Conducting Tax Examinations Abroad, Article 7 contains regulations regarding the Possibility of Declining a Request, Article 11 contains regulations regarding a Mutual Agreement Procedure.

Based on the information as provided by the Government of the States of Guernsey (that the TIEA entered into force on June 10, 2015) the TIEA shall have effect: 

a)     for criminal tax matters on June 10, 2015; and

b)     for all other matters covered in Article 1 on June 10, 2015, but only in respect of taxable periods beginning on or after June 10, 2015 or, where there is no taxable period, all charges to tax arising on or after June 10, 2015.

For further information click here to be forwarded to the text of the Agreement between the States of Guernsey and the Government of the Italian Republic on the Exchange of Information Relating to Tax Matters as available on the website of the Government of States of Guernsey.

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