• Guernsey Tax System

  • TAX RESIDENCY

    Tax Residency

    A company incorporated in Guernsey is considered to be tax resident in Guernsey by virtue of its incorporation.

    A company incorporated outside Guernsey is considered to be tax resident in Guernsey if its shareholder control is exercised by persons resident in Guernsey.

    Taxable Basis

    Guernsey tax resident companies are taxed on their worldwide income.

    Non-Guernsey tax resident companies are taxed only on income generated in Guernsey.

  • TAX ADMIN

    Taxable Period

    The taxable period for a company in Guernsey is the calendar year i.e. from 01/01 to 31/12 or any other 12-month period.

    Tax Returns

    Every company needs to submit an annual tax return by 30th of November of the following year.

    Tax Assessments

    The Commissioner has up to 6 months to issue a tax assessment.

  • CORPORATION TAX

    Corporation Tax

    The corporation tax rate in Guernsey is 0% for all income except for income from a banking business (taxed at 10%) and income from immovable property located in Guernsey (taxed at 20%).

  • DIVIDENDS

    Dividends from Foreign Investments

    Dividend income of a Guernsey company from foreign investments is not subject to tax in Guernsey.

    Dividends from Local Investments

    Dividend income of a Guernsey company from another Guernsey company is not subject to tax in Guernsey.

    Withholding Tax on Dividends

    Dividend payments by a Guernsey company to a foreign shareholder (company or individual) does not suffer any withholding tax.

    Dividend payments by a Guernsey company to another Guernsey company does not suffer any withholding tax.

  • INTEREST

    Interest Income

    Interest income of a Guernsey company is not taxable.

    Interest Expense Deductibility

    Interest expense is tax-deductible only if incurred wholly and exclusively for the production of taxable income.

    Withholding Tax on Interest

    Guernsey does not impose any withholding tax on payments to foreign recipients.

    There is no withholding tax on the payment of interest by one Guernsey Company to another Guernsey company.

  • ROYALTIES

    Royalty Income

    Royalty income of a Guernsey company is not taxable.

    Royalty Expense Deductibility

    Royalty expense incurred wholly and exclusively for the production of taxable income is allowed as tax-deductible.

    Withholding Tax on Royalties

    Guernsey does not impose any withholding tax on royalty payments to foreign recipients.

  • TAX LOSSES

    Ordinary Tax Losses

    Ordinary tax losses can be carried forward indefinitely and be set-off against taxable income of future years.

    In addition, losses from one class of income may be offset against profits from a different class of income in the same year provided that both classes of income are subject to tax at the same rate.

    There is no carry back of ordinary tax losses.

    Group Relief

    The Guernsey tax system allows for Guernsey resident companies to form a group for tax purposes whereby tax losses may be transferred between members of the tax group.

    A tax group is created when:

    • One company is the 90% subsidiary of another company.
    • Two companies are 90% subsidiary of another company (or individual).
  • CAPITAL GAINS

    Disposal of Shares by Foreign Shareholder

    The disposal of shares of a Guernsey company by its foreign shareholder is exempt from taxation in Guernsey.

    Capital Gains

    Capital gains are not taxable in Guernsey.

    Capital Losses

    Capital losses are not tax-deductible since capital gains are not taxable.

  • PARTNERSHIPS

    Partnership Profits

    General and Limited partnerships are treated as transparent entities for tax purposes which means that their profits are taxed directly in the hands of each partner.

  • BRANCHES

    Branch Profits

    The profit of a Guernsey Branch generated in Guernsey is taxable in the same manner as Guernsey companies (i.e. taxed at 0% except for business activities which are taxable at 10% or 20%).

    There is no tax in Guernsey on the remittance of the profit of a Guernsey Branch to its foreign head office.

  • STAMP DUTY

    Stamp Duty

    There is no stamp duty in Guernsey.

  • CAPITAL DUTY

    Capital Duty

    There is no capital duty in Guernsey.

  • VAT

    Guernsey does not levy VAT.