Guernsey

Personal income tax

20%.

Corporate income tax

0% on company profits, except for 10% tax on income from banking, insurance (relating to domestic business, intermediary and management), custody, fiduciary, fund administration, investment management for individuals, compliance and other related
activities provided to regulated businesses, operating an investment exchange, operating
an aircraft registry, and 20% tax on income from the ownership of land or buildings in Guernsey, operating a regulated utility company, retail in Guernsey (where taxable profits exceed £500k), importation and/or supply of oil and gas, cultivation of cannabis plants (or the use of those plants) and licensed production of controlled drugs.

Exchange restrictions

None.

Tax information exchange agreements

60 signed TIEAs as of August 2017.

As of July 2, 2019

Argentina, Japan, Australia, Korea (Republic of), Austria, Latvia, Bahamas, Lesotho, Belgium, Lithuania, Bermuda, Macau, Botswana, Mauritius, Brazil, Mexico, British Virgin Islands, Montserrat, Bulgaria, Netherlands, Canada, New Zealand, Cayman Islands, Norway, Chile, Poland, China, Portugal, Costa Rica, Romania, Czech Republic, San Marino, Denmark, Seychelles, Faroe Islands, Slovakia, Finland, Slovenia, France, South Africa.

Full Double Tax Treaties

Cyprus, Hong Kong, Isle of Man, Jersey, Liechtenstein, Luxembourg, Malta, Mauritius, Monaco, Qatar, Seychelles, Singapore, United Kingdom.

Partial Double Tax Treaties

Australia, Denmark (Individuals) (Shipping & Aircraft), Faroes (individuals) (Shipping & Aircraft), Finland (Individuals) (Shipping & Aircraft), Greenland (individuals) (Shipping & Aircraft), Iceland (individuals) (Shipping & Aircraft), Ireland, Japan, New Zealand, Norway (Individuals) (Shipping & Aircraft), Poland (Individuals) (Shipping & Aircraft), Sweden (Individuals) (Shipping & Aircraft).

Permitted currencies

Any.

Minimum authorised capital

No minimum authorised share capital is prescribed by the Companies (Guernsey) Law, 2008.

Minimum share issue

One share for a company limited by Shares.

Shelf companies

No, but standard Memorandum and Articles of Incorporation are available.

Timescale for new entities

One day standard, 15 minute incorporations possible where standard memorandum and articles from the Guernsey Registry are used.

Incorporation fees

Fee dependent on speed of incorporation ranging from £100 (24 hours) to £750 (15 minutes).

Annual fees

Annual validation fee dependent on type of company, ranging from £250 (non-regulated) to £1,000 (regulated) for non-cellular companies. Fee for cellular companies dependent on number of cells, at £750 plus £100 per incorporated cell and £50 per protected cell.

Minimum number

One.

Residency requirements

No, as a matter of corporate law. Regulated businesses will require resident directors.

Corporate directors

Yes, but not for regulated businesses.

Meetings/ frequency

AGM not required (subject to waiver resolution being passed).

Disclosure

Yes, but beneficial ownership not publicly available.

Bearer shares

No.

Minimum number

One.

Public share registry

No.

Meetings/ frequency

Accounts to be laid before AGM (subject to waiver resolution being passed).

Annual return

All Guernsey companies must file an annual validation with the Registry between 1 January and the last day of February (except companies incorporated in December the previous year).

Recent Legislation

• Beneficial Ownership of Legal Persons (Guernsey) (Amendment) Law, 2023
• Foundations (Guernsey) (Amendment) Law, 2023
• Limited Partnerships (Guernsey) (Amendment) Law, 2023
• Forfeiture of Assets in Civil Proceedings (Bailiwick of Guernsey) Law, 2023
• Prevention of Corruption (Bailiwick of Guernsey) (Amendment) Law, 2023
• Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022 commenced with part effect on 1.1.2023 and with full effect from 1.7.2023.
• Companies (Guernsey) Law, 2008 (Insolvency) (Amendment) Ordinance, 2020 as amended by the Companies (Guernsey) Law, 2008 (Insolvency) (Amendment) Ordinance, 2021 and came into effect 1.1.2023
• Beneficial Ownership of Legal Persons (Guernsey) (Amendment) Law, 2023
• Foundations (Guernsey) (Amendment) Law, 2023
• Limited Partnerships (Guernsey) (Amendment) Law, 2023
• Prevention of Corruption (Bailiwick of Guernsey) (Amendment) Law, 2023
• Forfeiture of Assets in Civil Proceedings (Bailiwick of Guernsey) Law, 2023
• Terrorism and Crime (Bailiwick of Guernsey) (Amendment) Ordinance, 2024
• Sanctions and Terrorist Asset Freezing (Bailiwick of Guernsey) (Amendment) Ordinance, 2023
• Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No.5) Ordinance, 2023
• Criminal Justice (Miscellaneous Amendments - Deferred Prosecution Agreements) (Bailiwick of Guernsey) Ordinance, 2023
• Trading Standards (Fair Trading) (Guernsey) Ordinance, 2023 e.i.f. 2.10.2023 commenced pursuant to the Trading Standards (Fair Trading) (Guernsey) Ordinance 2023 (Commencement) Regulations 2023
• Preferred Debts (Insurance Policyholders) (Bailiwick of Guernsey) (Amendment) Ordinance, 2023
• Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 (Amendment) Ordinance, 2023
• Beneficial Ownership of Legal Persons (Guernsey) Law, 2017 (Amendment – Enforcement etc) Ordinance, 2023
• Companies (Guernsey) Law, 2008 (Amendment) Ordinance, 2023
• Limited Liability Partnerships (Guernsey) Law, 2013 (Amendment) Ordinance, 2023
• Foundations (Guernsey) Law, 2012 (Amendment) Ordinance, 2023
• Criminal Justice (Proceeds of Crime and Drug Trafficking – Money Laundering, etc) (Bailiwick of Guernsey) (Amendment) Ordinance, 2023
• Criminal Justice (Proceeds of Crime and Drug Trafficking) (Bailiwick of Guernsey) (Amendment) Ordinance, 2023
• Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No.3) Ordinance, 2023
• Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No.4) Ordinance, 2023
• Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No.2) Ordinance, 2023
• Criminal Justice (International Co-operation) (Bailiwick of Guernsey) (Amendment) Ordinance, 2023
• Criminal Justice (Miscellaneous Amendments - Preventative Offences) (Bailiwick of Guernsey) Ordinance, 2023
• Criminal Justice (Terrorism and Disclosure) (Bailiwick of Guernsey) (Amendment) Ordinance, 2023
• ORC 1 - 2023 - The Company Insolvency Rules (Application To Disclaim Onerous Property) Rules, 2023
• ORC 2 - 2023 - Forfeiture of Money etc in Civil Proceedings (Bailiwick of Guernsey) (Amendment) Rules, 2023
• No. 27 - The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment of Schedule 3) (No.2) Regulations 2024
• No. 26 - The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Professional Qualifications - Accountants and Non-Locally Qualified L
• No. 25 - The Sanctions (Bailiwick of Guernsey) Law 2018 (Amendment) Regulations 2024
• No. 24 - The Terrorist Asset-Freezing (Bailiwick of Guernsey) Law 2011 (Amendment) Regulations 2024
• No. 22 - The Beneficial Ownership (Definition) (Amendment) Regulations 2024
• No. 21 - The Economic and Financial Crime Bureau and Financial Intelligence Unit (Bailiwick of Guernsey) Law 2022 (Amendment) Regulations, 2024
• No. 20 - The Criminal Justice (Miscellaneous Amendments - Deferred Prosecution Agreements) (B of G) Ordinance, 2023 (Commencement) Regulations, 2024
• No. 19 - The Criminal Justice (Miscellaneous Amendments - Preventative Offences) (B of G) Ordinance 2023 (Commencement) Regulations, 2024
• No. 18 - The Forfeiture of Assets in Civil Proceedings (Codes of Practice) (Bailiwick of Guernsey) Order, 2024
• No. 17 - The Forfeiture of Assets in Civil Proceedings (Commencement Amendment and Miscellaneous Provisions) (Bailiwick of Guernsey) Regulations, 2024
• No. 16 - The Administrative Forfeiture of Assets (Forfeiture Notices) (Bailiwick of Guernsey) Regulations, 2024
• No. 15 - The Insurance Business (Solvency) (Amendment) Rules, 2024
• No. 14 - The Insurance Business (Amendment) Rules, 2024
• No. 13 - The Insurance Managers (Amendment) Rules, 2024
• No. 12 - The Limited Liability Partnerships (Guernsey) Law, 2013 (Amendment) Regulations, 2024
• No. 11 - The Limited Partnerships (Annual Validations) (Amendment) Regulations, 2024
• No. 10 - The Foundations (Annual Renewal) (Amendment) Regulations, 2024
• No. 8 - The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment of Schedule 3) Regulations, 2024
• No. 3 - The Financial Services Commission (Fees)(Amendment) Regulations, 2024
• No. 146 - Handbook on Countering Financial Crime and Terrorist Financing
• No. 144 - Limited Partnerships (Registrar) (Civil Penalties) (Amendment) (No.2) Regulations 2023
• No. 143 - Foundations (Registrar) (Civil Penalties) (Amendment) (No.3) Regulations 2023
• No. 142 - Limited Liability Partnerships (Registrar) (Fees and Penalties) (Amendment) (No.3) Regulations 2023
• No. 141 - Companies (Registrar) (Fees and Penalties) (Amendment) (No.3) Regulations 2023
• No. 135 - The Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Amendment - Iran) Regulations, 2023
• No. 133 - The Document Duty (Anti-Avoidance) (Fees) Regulations, 2023
• No. 130 - The Criminal Justice (Miscellaneous Amendments - Preventative Offences) (B of G) Ordinance, 2023 (Commencement) Regulations, 2023
• No. 127 - The Financial Services Commission (Fees and Administrative Penalties) Regulations, 2023
• No. 126 - The Criminal Justice (PoC) (BoG) (Fees) (Amendment) Regulations, 2023
• No. 122 - The Regulation of Fiduciaries etc (Amendment of Companies Law) Regulations, 2023
• No. 121 - The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No.3) Ordinance 2023 (Specified Jurisdictions) Regulations, 2023
• No. 119 - Beneficial Ownership of Legal Persons (Nominee Relationships (Amendment) Regulations 2023
• No. 118 - The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No. 4) Ordinance 2023 (Commencement) (Amendment) Regulations 2023
• No. 117 - Limited Partnerships (Annual Validations) (Amendment) Regulations 2023
• No. 116 - Limited Partnerships (Guernsey) Law 1995 (Amendment) (No.2) Regulations 2023
• No. 115 - Limited Liability Partnerships (Guernsey) Law 2013 (Amendment) Regulations 2023
• No. 114 - LLPs (Annual Validations) (Amendment) Regulations 2023
• No. 113 - Foundations (Guernsey) Law 2012 (Annual Renewal and Fees) (Amendment) Regulations 2024
• No. 104 - Companies (Recognition of Auditors) (Amendment) Regulations, 2023
• No. 88 - Guernsey Finance LBG (Levy) (Guernsey) (Amendment) Regulations, 2023
• Natural Capital Fund Rules were amended by the Natural Capital Fund (Amendment) Rules, 2023
• The Regulation of Fiduciaries etc (Amendment of Companies Law) Regulations, 2023
• The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) (Amendment) (No.3) Ordinance 2023 (Specified Jurisdictions) Regulations, 2023
• Beneficial Ownership of Legal Persons (Nominee Relationships (Amendment) Regulations 2023
• Limited Partnerships (Annual Validations) (Amendment) Regulations 2023
• Limited Partnerships (Guernsey) Law 1995 (Amendment) (No.2) Regulations 2023
• Limited Liability Partnerships (Guernsey) Law 2013 (Amendment) Regulations 2023
• LLPs (Annual Validations) (Amendment) Regulations 2023
• Foundations (Guernsey) Law 2012 (Annual Renewal and Fees) (Amendment) Regulations
• Companies (Guernsey) Law 2008 (Annual Validation) (Amendment) Regulations 2023
• Foundations (Registrar) (Civil Penalties) (Amendment) (No.2) Regulations 2023
• Companies (Recognition of Auditors) (Amendment) Regulations, 2023
• Guernsey Finance LBG (Levy) (Guernsey) (Amendment) Regulations, 2023
• Limited Partnerships (Registrar) (Civil Penalties) (Amendment) Regulations, 2023
• Limited Liability Partnerships (Registrar) (Fees and Penalties) (Amendment) (No.2) Regulations, 2023
• Foundations (Registrar) (Civil Penalties) (Amendment) Regulations, 2023

Pending Legislation

• Terrorism and Crime (Bailiwick of Guernsey) (Amendment) (No. 2) Ordinance, 2024

Audit requirements

Yes unless waived by members' waiver resolution (various exemptions available but not for regulated businesses, or 'large companies' under the Companies (Audit Exemption) Regulations, 2008).

Registered office

Yes.

Domicile issues

Migration of companies in/out of jurisdiction permitted where reciprocal legislation exists in corresponding jurisdiction.

Company naming restrictions

Yes, compulsory wording such as 'ICC' and 'PCC' for incorporated or protected cell companies, and prohibited wording such as 'Royal', 'Bank', or 'Fund', where there is no such connection.