Ireland Welcomes Bilateral Agreements With Jersey And Guernsey

by Jason Gorringe, Tax-News.com, London

03 April 2009

The Revenue Commissioners, Ireland's tax authority, has welcomed the signing of tax cooperation agreements between Ireland and Jersey, and Ireland and Guernsey on March 26.

There are two agreements with each:

• a tax information exchange agreement, and
• an agreement for affording relief from double taxation with respect to certain income of individuals and establishing a mutual agreement procedure in connection with the adjustment of profits of associated enterprises.

The Tax Information Exchange Agreement (TIEA) is based on a model agreement developed by the Organisation for Economic Co-operation and Development (OECD). It will allow the Irish Revenue Commissioners to request information from their Jersey or Guernsey counterparts that is relevant to an Irish tax investigation. Such information would typically relate to bank accounts or the beneficial ownership of companies or trusts. Likewise, Jersey and Guernsey authorities may request the Revenue Commissioners to obtain and provide information of relevance to their tax investigations.

As a consequence of the new relationship, an agreement for the avoidance of double taxation with respect to income and corporation taxes was also signed with both jurisdictions. This will reduce the potential for double taxation of certain income of individuals.

In a joint declaration signed between Ireland and both jurisdictions, the three parties agreed to continue to work together in a spirit of transparency and cooperation to examine what measures could be adopted to further enhance and broaden their bilateral political and economic relationship with Ireland.

Ireland welcomed the commitment of Jersey and Guernsey to implement the OECD standards of transparency and exchange of information in tax matters and their willingness to enter into TIEAs. The signing of the agreements represents a new chapter in relations between Ireland and both jurisdictions, concluded Revenue’s release.

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