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5.4. Tax Base for Non-Resident Entities

Non-resident entities operating in Guernsey through a permanent establishment (‘PE’) are subject to tax on income sourced from Guernsey except disregarded company income such as Guernsey-sourced bank interest.

Disregarded income is income arising to non-residents not subject to tax in Guernsey such as company deemed distributions, deposit interest, royalties or any other income of similar nature and director’s fees, other than income from land and buildings located in Guernsey.

Non-resident entities deriving income from sources in Guernsey without a PE are subject to withholding tax on their income (See Sec. 8.2.2. below for tax rates).