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June 18, 2026

Agreement between the Government of the KINGDOM OF BAHRAIN and THE STATES OF GUERNSEY for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance

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

Article 1
Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Parties.

Article 2
Taxes Covered