The Government of Guernsey has published the synthesized text of the 2014 income and capital tax treaty with Cyprus as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text was prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaty and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2014 Guernsey-Cyprus Tax Treaty as follows:

• with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
• with respect to all other taxes levied with respect to taxable periods beginning on or after 1 November 2020.

MLI synthesized texts of Guernsey's tax treaties can be found on the Double taxation arrangements webpage of the Government website.