Article 1
Persons Covered
This Agreement shall apply to persons who are residents of one or both of the Parties.
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Website Last updated:
June 18, 2026
The Government of the Kingdom of Bahrain and the States of Guernsey,
Desiring to further develop their economic relationship and to enhance their co-operation in tax matters,
Intending to conclude an Agreement for the elimination of double taxation with respect to the taxes covered by this Agreement without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third jurisdictions),
Have agreed as follows:
Contents
Article 1 - Persons Covered
Article 2 - Taxes Covered
Article 3 - General Definitions
Article 4 - Resident
Article 5 - Permanent Establishment
Article 6 - Income from Immovable Property
Article 7 - Business Profits
Article 8 - Shipping and Air Transport
Article 9 - Associated Enterprises
Article 10 - Dividends
Article 11 - Income from Debt-Claims
Article 12 - Royalties
Article 13 - Capital Gains
Article 14 - Income from Employment
Article 15 - Directors' Fees
Article 16 - Artistes and Sportsmen
Article 17 - Pensions
Article 18 - Government Service
Article 19 - Students
Article 20 - Other Income
Article 21 - Elimination of Double Taxation
Article 22 - Non-Discrimination
Article 23 - Mutual Agreement Procedure
Article 24 - Exchange of Information
Article 25 - Members of Diplomatic Missions and Consular Posts
Article 26 - Entitlement to Benefits
Article 27 - Signature and Entry into Force
Article 28 - Termination
This Agreement shall apply to persons who are residents of one or both of the Parties.