The amending protocol to the individual income tax treaty between Guernsey and Poland was signed on 29 May 2022. The protocol is the first to amend the treaty and includes the following changes:

• The title and preamble are replaced in line with OECD BEPS standards;
• Article 3 (Definitions) is updated with respect to the "competent authority" of Guernsey;
• Article 9 (Mutual Agreement Procedure) is updated with respect to the presentation of a case by an individual;
• Article 13A (Entitlement to Benefits) is added, providing that a benefit under the treaty shall not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the treaty.

The protocol will enter into force on the last day of the month following the month in which the ratification instruments are exchanged and will apply from 1 January of the year following its entry into force.