Guernsey

Research notes

Guernsey — family-office tax dossier

Last reviewed: 2026-10-16 Tax year: 2026 Reviewer: research agent (Claude), unreviewed by a tax adviser

Summary

Crown Dependency outside the UK and EU. No capital gains tax, no inheritance or gift tax, no wealth tax. Income including dividends is taxed at a flat 20%, with optional caps of £160,000 (foreign income) or £320,000 (worldwide), and a £60,000 cap for four years for newcomers buying Open Market property. A GST was approved in October 2026 (from about 2028).

Residence and eligibility

Day-count categories: principally resident (182+ days in the year); solely resident (91+ days and not 91+ days elsewhere); resident only (91-182 days, or 35+ days with 365+ days over the previous four years). Resident-only individuals may pay a standard charge (£50,000 for 2026) instead of tax on non-Guernsey income.

• Open Market housing (EU, US, OTHER): Anyone may live in Part A Open Market property without a housing licence. Non-British/Irish nationals also need immigration permission under Bailiwick rules (UK-style; not researched in detail).

Standard regime eligibility: Tax residence in Guernsey. Newcomers without local housing status can generally only live in Open Market (Part A) housing.

Capital gains

Guernsey has no capital gains tax. Gains by a resident private investor on securities, a private business or real estate are not taxed unless the activity is a trade (taxed as income at 20%).

• rate basis: No capital gains tax (Carey Olsen: 'no ... capital gains taxes'); income tax at 20% applies to income only.
• important exceptions: From 2026, repayments of non-commercial shareholder loans from personal investment companies are treated as dividends (anti-avoidance).
• professional trader: Dealing in shares or land as a trade is taxed as income at 20%; Guernsey property development profits are taxed at 20%.
• holding period rules: None.
• foreign assets: Foreign gains are equally untaxed.
• JSON values: {"headline_rate": 0.0, "rates": {"listed_securities_domestic": 0.0, "listed_securities_foreign": 0.0, "private_business_sale": 0.0, "real_estate_local": 0.0, "real_estate_foreign": 0.0}}
• Confidence / verification: high / partially_verified (tax year 2026)

Dividends

Dividends are taxed as income at a flat 20%. Guernsey companies paying dividends to resident individuals deduct tax at source up to 20% (20% if the company paid 0%). Residents can elect tax caps (see special regimes).

• rate basis: Flat 20% income tax rate on net income after allowances (PwC). Personal allowance £15,200 for 2026, withdrawn above £85,000 of income. Foreign tax relief where there is no treaty (unilateral relief) is the lower of the foreign tax and three-quarters of the effective Guernsey rate on the income (Revenue Service guide): at the 20% top rate that is 15% of the gross dividend, so a 15% withholding is credited in full.
• exemptions thresholds: Personal allowance £15,200 (2026), withdrawn from £85,000 of income.
• withholding outbound: 0% withholding on dividends to non-residents under domestic law; dividends to Guernsey-resident individuals carry a deduction making up tax to 20%.
• treaty network: 14 comprehensive double tax agreements (incl. UK, Jersey, Isle of Man, Luxembourg, Malta, Cyprus, Singapore, Hong Kong); no US income tax treaty, so US dividends suffer 30% US withholding. Foreign tax relieved by credit.
• JSON values: {"headline_rate": 0.2, "domestic_rate": 0.2, "foreign_gross_rate": 0.2, "foreign_tax_credit": "credit"}
• Confidence / verification: high / verified (tax year 2026)
• Open question: The Revenue Service guide read for unilateral relief is a 2017 document; the related Statement of Practice M8 was withdrawn on 19 August 2024 and its replacement was not found.

Inheritance and gifts to children

No inheritance, estate or gift tax. A probate registry fee applies to personal (movable) estate: £225 up to £80,000 plus £50 per further £10,000 (0.5%), capped at £250,000 for estates above about £50m. Worldwide personal estate counts if no grant has been taken elsewhere.

• exemptions thresholds: Probate Registry fee on the gross value of the personal estate (no deduction for debts): GBP 225 plus GBP 50 for each additional GBP 10,000 above GBP 80,000, plus small amounts for extra documents; capped at GBP 250,000 above GBP 50,030,000 (Mourant, 27 February 2026). Not indexed. Guernsey real property is outside the grant. Older guides (Carey Olsen 2020) show £35 per £10,000 (0.35%), so the scale has risen.
• important exceptions: Lifetime gifts attract no fee, and assets already covered by a foreign grant are valued on the Guernsey estate only.
• foreign assets: Worldwide movable estate counts for the probate fee unless probate has been obtained in another jurisdiction.
• gift tax: No gift tax.
• domicile rules: No tax, so no domicile test for tax. Families arriving from the UK remain within UK IHT under the residence-based test from 6 April 2025 for up to 10 years after leaving, depending on years of UK residence.
• JSON values: {"basis": "none", "children_treatment": "fully_exempt", "exemption": 0, "other_transfer_cost_rate": 0.005, "gifts_same_as_inheritance": false}
• Confidence / verification: medium / partially_verified (tax year 2026)
• Open question: Official Probate Registry fee schedule not located; figures from Mourant guide dated 27 Feb 2026.

Wealth tax

No wealth tax or net worth tax.

• property tax note: Tax on Real Property (TRP) is an annual property tax based on property size and use (not a wealth tax). Document duty applies to property purchases; the extra 2% on second/buy-to-let properties was removed in the 2026 Budget.
• JSON values: {"type": "none"}
• Confidence / verification: high / verified (tax year 2026)

Special regimes

Income tax cap (tax_cap)

A Guernsey resident can elect to cap income tax on non-Guernsey-source income (including Guernsey bank interest) at £160,000 a year, or on worldwide income at £320,000 a year (2026, unchanged since 2024). Guernsey property income is taxed at 20% on top. Since 2023 each spouse elects individually.

• Eligibility: Any Guernsey-resident individual, by annual election. Worthwhile when 20% of foreign income exceeds £160,000 (about £800,000 of income).
• Duration (years): indefinite
• Why it does not expire: No time limit: any Guernsey resident can claim the cap each year under sections 39B-39E and the Sixth Schedule of the Income Tax (Guernsey) Law, 1975 (gov.gg tax cap page). The cap amounts are set in each annual Budget; it is apportioned in the year of arrival or departure.
• Lump sum / cap in JSON: 160,000 GBP a year, covers foreign_dividends, foreign_capital_gains, foreign_income_all. £160,000 is a maximum, not a fixed charge: tax is the lower of 20% of non-Guernsey income and the cap. The £320,000 cap covers worldwide income. Per individual since independent taxation in 2023 (couple: up to £320,000 on foreign income).

Dividends under this regime: Once the £160,000 cap binds, further foreign dividends carry no Guernsey tax. Guernsey-source dividends stay at 20% unless the £320,000 worldwide cap is chosen.

• rate basis: Marginal rate 0% on foreign income above the cap threshold; cap modelled as the lump sum.
• withholding outbound: 0% on dividends to non-residents.
• treaty network: As standard regime.
• JSON values: {"headline_rate": 0.0, "domestic_rate": 0.2, "foreign_gross_rate": 0.0, "foreign_tax_credit": "not_applicable"}
• Confidence / verification: high / verified (tax year 2026)

Open Market new-resident tax cap (open_market_cap)

A newcomer who buys an Open Market (Part A) property with at least £50,000 of document duty can cap income tax on worldwide income (except Guernsey property income) at £60,000 a year for the arrival year and the following three years. After that the ordinary caps apply.

• Eligibility: Not Guernsey resident in the previous three years; purchase of a Part A Open Market property within 12 months of becoming resident, paying at least £50,000 document duty (roughly a £1.3m+ property).
• Duration (years): 4
• Lump sum / cap in JSON: 60,000 GBP a year, covers foreign_dividends, foreign_capital_gains, foreign_income_all, domestic_income. Maximum, not a fixed charge. Guernsey land and property income excluded (taxed at 20%). Amount £60,000 since 2024, unchanged for 2026. A June 2026 proposal by Innovate Guernsey to raise it has not been adopted as far as found.

Dividends under this regime: During the four capped years, dividends above about £300,000 of income carry no further Guernsey tax because total tax is capped at £60,000.

• rate basis: Marginal rate 0% once 20% of income exceeds £60,000.
• withholding outbound: 0% on dividends to non-residents.
• treaty network: As standard regime.
• JSON values: {"headline_rate": 0.0, "domestic_rate": 0.0, "foreign_gross_rate": 0.0, "foreign_tax_credit": "not_applicable"}
• Confidence / verification: high / verified (tax year 2026)

Holding structures

Structure modelled: Guernsey investment holding company, regime id `holding_company`.

• Company tax: the standard company rate is 0% (Revenue Service; PwC); there is no capital gains tax. Dividends and gains in the company are untaxed (JSON dividends 0, exemption; gains 0); foreign withholding tax is a final cost. 10% (banking, fiduciary and other regulated activities) and 20% (Guernsey property, large retail and similar) apply to listed activities only.
• Payout: if a company's income is taxed at less than 20%, a tax charge arises when a distribution is paid to a Guernsey-resident beneficial member; the company deducts it and pays it to the Revenue Service. A 0%-taxed company therefore deducts the full 20% (payout_tax_rate 0.20). Distributions to non-residents carry no charge (Revenue Service, tax information for companies).
• Retained profits: not taxed on the member in the sources read. Anti-avoidance: preferentially priced loans to participators are treated as income, and repayments of non-commercial shareholder loans from personal investment companies are treated as dividends from 2026.
• Inheritance: the shares are personal estate, so the probate fee applies as for personal holding; the metric is the standard regime's.
• Running costs: not sourced (omitted). US citizens are excluded (CFC/PFIC rules).
• Considered, not added: Guernsey foundations and trusts (no income tax saving for a resident family; not sourced). The tax_cap regime has a path: the caps are maximums, and the engine charges the lower of the cap and the ordinary tax. open_market_cap has no path (it needs an Open Market property purchase and lasts four years).

Company taxation (kept separate from personal tax)

Headline CIT rate in JSON: 0.0.

General corporate rate 0%; 10% for banking, fiduciary, fund administration and similar regulated business; 20% for Guernsey property income, utilities and large retail. Pillar Two (domestic top-up tax and multinational top-up tax) from 1 January 2025 for groups with €750m+ revenue. No withholding tax on dividends to non-residents.

Cost of living notes

City: St Peter Port.

• International school fee (annual, per child): 16,995 GBP (2026). Elizabeth College (independent, Years 7-13 incl. sixth form), Upper School day fee 2026-27: £5,665 per term, £16,995 a year, from the school's fee page. Source: Elizabeth College - School fees.
• Prime rent (monthly): £4,875 (2026). Median of a small sample: the only 4 long-let homes with 4-5 bedrooms and a stated rent on Guernsey agency sites on 2026-10-15: Swoffers - Connaught House, St Peter Port, 4 bed, Open Market, £72,000 a year (£6,000 pcm); Confidential Instruction, St Martin's, 5 bed, Local Market, £5,000 pcm; Central Park, St Peter Port, 4 bed, Local Market, £3,850 pcm; Livingroom - Valley Lodge, Forest, 4 bed, Open Market, £4,750 pcm (let). Price-on-application listings and 3 Belle Vue (3 bed per Swoffers and Savills) excluded; Savills Guernsey had no 4+ bedroom lettings. A newly arriving family without a housing licence can rent only Open Market property (the two Open Market rents: £4,750 and £6,000). Indicative only. Sources: Swoffers rentals, Livingroom rentals, Savills Guernsey rentals.
• For scale, the official Local Market mix-adjusted average advertised rent was £2,075 a month in Q2 2025 (Guernsey Facts and Figures 2025), across all sizes. Health insurance, housekeeper and price per m² not sourced.

Indicator overrides (non-tax scoring). Used because the automatic World Bank/UNDP feeds have no value for this jurisdiction:

• life_expectancy = 83.6 (2024): Life expectancy at birth, three-year average 2022-2024, provisional (Table 1.1 and Figure 3.15). Source: Guernsey Facts and Figures 2025.
• homicide_rate = 0.0 (2025): The full list of recorded 'Violence Against the Person' offences for 2025 contains no murder or manslaughter; the 2024 Bailiwick Law Enforcement Annual Report's list also has none. Zero homicides on a population of about 64,000. Source: Guernsey Police Annual Report 2025.

US citizens: No US-Guernsey income tax treaty; US tax applies on worldwide income with credit for Guernsey tax. Guernsey's caps reduce the local credit available.

Open questions

• GST: on 2 October 2026 the States carried P.2026/49 (22-17) directing a GST package with income tax and social security mitigations (reported starting rate 3%, possibly rising to 5%; supporters target 2028). No law made, no start date; income tax effects for high earners unknown (source: lookuptax.com tracking summary, not an official record).
• Non-employed residents pay social security contributions on income up to an upper limit; not modelled here.
• Cost-of-living items not sourced (no official 2026 senior fee found for Elizabeth College).
• Needs an engine change: the Guernsey tax caps (GBP 160,000 on non-Guernsey income, GBP 320,000 worldwide, GBP 60,000 for four years for Open Market buyers) are maximums on the income tax otherwise due, elected each year by each spouse; the tax is the lower of the cap and the normal tax. The engine charges the lump sum as a fixed amount. For the reference family (about GBP 520,000 of dividends, 15% withholding credited in full) the normal tax is about 5% of the dividends, below every cap, so the recipe has no cap paths: a fixed charge would overstate the tax by GBP 34,000 to GBP 134,000 a year.

Sources

• Probate and estate administration for Guernsey domiciliaries: <https://www.careyolsen.com/sites/default/files/CO_GSY_Probate-and-estate-administration-for-Guernsey-domiciliaries_19-5-20.pdf>
• Guernsey - Individual - Taxes on personal income: <https://taxsummaries.pwc.com/guernsey/individual/taxes-on-personal-income>
• Guernsey - Corporate - Withholding taxes: <https://taxsummaries.pwc.com/guernsey/corporate/withholding-taxes>
• Guernsey Budget 2026: <https://www.grantthorntonci.com/News-Centre/budget-responses/guernsey-budget-2026/>
• Guernsey - Individual - Other taxes: <https://taxsummaries.pwc.com/guernsey/individual/other-taxes>
• Guernsey probate (guide dated 27 February 2026): <https://www.mourant.com/news-and-views/guides/guernsey--probate>
• Tax cap (Revenue Service guidance): <https://www.gov.gg/taxcap>
• Monetary values table (income tax allowances, caps, standard charge, 2018-2024): <https://gov.gg/CHttpHandler.ashx?id=174308&p=0>
• Guernsey - Individual - Residence: <https://taxsummaries.pwc.com/guernsey/individual/residence>
• States approve GST package (P.2026/49): <https://lookuptax.com/tax-changes/guernsey/states-approve-gst-package-2026>
• Guernsey - Corporate - Taxes on corporate income: <https://taxsummaries.pwc.com/guernsey/corporate/taxes-on-corporate-income>
• Elizabeth College - School fees: <https://elizabethcollege.gg/school-fees/>
• Guernsey Facts and Figures 2025: <https://www.gov.gg/CHttpHandler.ashx?id=194705&p=0>
• Guernsey Police Annual Report 2025: <https://www.guernsey.police.uk/CHttpHandler.ashx?id=200660&p=0>
• Swoffers - Property search: rentals: <https://swoffers.co.uk/property-search?market=rentals>
• Livingroom - Rent: <https://www.livingroomproperty.com/rent>
• Savills - Properties to rent in Guernsey: <https://search.savills.com/gg/en/list/property-to-rent/channel-islands/guernsey>
• Guernsey Income Tax (Revenue Service guide, section C): <https://www.gov.gg/CHttpHandler.ashx?id=101375&p=0>
• Tax information for companies (Revenue Service): <https://gov.gg/companytax>
• Guernsey - Corporate - Taxes on corporate income: <https://taxsummaries.pwc.com/guernsey/corporate/taxes-on-corporate-income>
• Guernsey probate (Mourant guide, 27 February 2026): <https://www.mourant.com/guides/guernsey-probate/>

Change log

• 2026-10-15: initial research.
• 2026-10-15: data-quality pass: added Elizabeth College fee (£16,995, 2026-27); rent still not sourced; added duration_note to the tax cap; added indicator overrides: life expectancy 83.6 (Facts and Figures 2025) and homicide rate 0.0 (Guernsey Police Annual Report 2025).
• 2026-10-15 (household cost pass): added prime rent £4,875 a month, the median of the only 4 priced 4-5 bedroom long-lets on Swoffers and Livingroom (Savills had none); small sample, described as such.
• 2026-10-15: family rent re-checked against the upper-middle-class standard: kept.
• 2026-10-16: recipe pass (data/recipes/GGY.json). Added the holding_company structure regime (0% company, 20% deducted from distributions to resident members; Revenue Service). Dividend text: unilateral relief rule from the Revenue Service guide (the existing 'credit' flag stays correct at a 15% withholding). Probate text: fee scale restated with the base amount. Tax caps given no recipe path; open question on the lower-of rule recorded.