Guernsey has signed a bilateral Tax Information Exchange
Agreement (TIEA) with South Africa, taking the total number of
TIEAs signed by the Island to 22.
Guernsey's Chief Minister,
Lyndon Trott, signed the bilateral TIEA with the Government of the
Republic of South Africa on 21st February 2011. It
follows Guernsey signing TIEAs with Canada and Romania during
The Chief Minister said: "This
TIEA, with South Africa, is the twenty-second TIEA that Guernsey
has signed to date and the third agreement signed during 2011. I am
particularly delighted that, not only is this Guernsey's first
TIEA with a country in the African continent but also that South
Africa's first TIEA is with Guernsey."
In a joint declaration, signed at
the same time as the TIEA, both South Africa and Guernsey expressed
their wish to strengthen their economic and trading relationship,
each country recognising the other's commitment to operating
financial regulatory systems that meet the highest international
standards in order to combat money laundering, terrorist financing
and other financial and fiscal crimes.
The joint declaration makes it clear
that the broadening of the political and economic relationship
between South Africa and Guernsey will be an ongoing process and
that, following the entry into force of the TIEA, measures will be
examined which may enhance that relationship, including elements of
double taxation, discrimination and other undesired tax
Under the terms of a TIEA, Guernsey
will, on request, exchange bank and other information relating to
both criminal and civil tax matters.
Guernsey has now signed TIEAs with 22 territories: Australia,
Canada, China, Denmark, Faroe Islands, Finland, France, Germany,
Greece, Greenland, Iceland, Ireland, Netherlands, New Zealand,
Norway, Portugal, Romania, San Marino, South Africa, Sweden, United
Kingdom and the United States of America
In its judgment of 19th September 2016 in In the matter of D, E and F Trusts  JRC 166C, the Royal Court applied, for the first time, the statutory mistake provisions embodied in Article 47E of the Trusts (Jersey) Law 1984.
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