In addition, Guernsey has entered into agreements in part on double taxation with the following legal systems: France has signed similar agreements with the Isle of Man (which came into force on 4 October 2010), BVI, San Marino, Andorra, Gibraltar, Liechtenstein, Turks and Caicos Islands, Caiman Islands, Bermuda, Vanuatu and Uruguay. This agreement, published in April 2002, is not a binding instrument, but includes two models of bilateral agreements. Many bilateral agreements are based on this agreement (see below). France has recently introduced new measures providing for tougher penalties for fraud in countries that do not have an agreement on the exchange of banking information with France. Prescription status has been increased to 10 years instead of three if these countries have not been included. As explained in two new declarations of practice of 12 April 2010, failure to mention the reference to a foreign account opened, used or closed by French residents will result in a fine of 1,500 euros (compared to 750 euros previously) or 10,000 euros for each account held in a state that does not allow access to bank information. Similarly, the non-reporting of life insurance contracts is now punishable by the same penalties. Previously, Guernsey did not generally enter into tax treaties as a matter of policy. However, on 12 March 2012, the island signed a double taxation agreement with Malta. Guernsey has now implemented a total of 13 comprehensive double taxation agreements, as shown in the table below: The scope of the Tax Information Exchange Agreement between France and Jersey and Guernsey The Australian and Guernsey governments have signed an agreement to exchange tax information. The agreement provides for the exchange of information on request for both civil and criminal purposes. Under Article 164 C of the French tax code, non-French residents (there are special provisions if they are French nationals) are taxed on the fictitious income of all French residential real estate from which they can benefit, even if they do not own it.

The fictitious income is calculated as being triple the annual rental value of the property in France. If the property is leased, a fictitious income tax remains in effect, but only if the fictitious income is higher than the real French rental income. Guernsey 2018 and the UK Double Taxation Convention, which were not signed in force on 2 July 2018, have been added to the page. In addition, Australia and Guernsey have signed an agreement on the allocation of tax duties in accordance with certain individuals and the establishment of a mutual agreement procedure for transfer pricing adjustments. This agreement will distribute tax duties on certain incomes of retirees, government employees and students and provide a mechanism for resolving transfer pricing disputes. However, TIEA only envisages the exchange of information on specific requests and under strict conditions. It is not a question of „fishing expeditions“ by the tax authorities. . On 2 July 2018, a new agreement and comprehensive protocol on double taxation was signed in London. It came into force on 7 January 2019 and comes into force: the TIEA is not a true double taxation agreement aimed at avoiding double taxation and preventing tax evasion. Their scope is in fact limited to tax exchanges between the two countries.

Historically, companies in Jersey and Guernsey could not apply for a conditional tax exemption for 3% of French taxes. These two TIEAs must be considered as a provision of mutual assistance contained in the tax treaty. One of the main advantages of TIEA is therefore that investment funds and real estate structures in France should be exempt from taxes of 3%.