Guernsey

Company Formation & Tax
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• Standard company (limited by shares) or protected cell company (PCC) for fund/insurance structures
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• 0% corporate tax for most companies (10% for banking, insurance intermediation, 20% for certain utilities and domestic property businesses)
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• No capital gains tax, no inheritance tax, no VAT (though similar goods and services tax applies at lower rates)
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• Personal income tax 20% flat rate (no national insurance, so effective personal tax burden lower than UK)
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• Fast incorporation, strong corporate law framework
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• Popular for investment funds, fund administration, trust companies, insurance (captives, re-insurance), holding companies

Fund Structures & Administration
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• Leading domicile for private equity funds, closed-ended funds, property funds
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• Open-ended funds, hedge funds (though Cayman more dominant for hedge funds)
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• Authorized funds (regulated by GFSC): Full regulatory oversight, can market to retail investors
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• Registered funds (lighter regime): For professional/experienced investors only, notification to GFSC required
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• Unregulated funds: Private placements, family vehicles (no GFSC involvement if structured correctly)
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• Protected cell companies (PCCs) allow multiple segregated portfolios under one legal entity
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• World-class fund administration sector (numerous global administrators present)

Trust & Fiduciary Services

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• Strong trust law framework (centuries of expertise)
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• Popular jurisdiction for family trusts, asset protection trusts, purpose trusts
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• Professional trustee sector highly regulated and sophisticated
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• Integration with corporate structures for complex family wealth planning
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• Confidentiality balanced with OECD/UK transparency requirements (beneficial ownership registers, CRS compliance)
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• Used extensively by UK and international families for estate planning, succession

Practical Considerations
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• British Crown Dependency (self-governing, UK responsible for defense/foreign affairs)
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• Political stability, rule of law, independent judiciary
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• English-speaking, English common law system
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• High quality professional services (lawyers, accountants, administrators among best globally)
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• OECD/FATF compliant, not on grey lists
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• Close ties to UK and Channel Islands (Jersey)
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• High cost of living and operating costs (premium jurisdiction)
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• Small island (pop. ~65,000), limited domestic economy
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• Ideal for: investment funds (especially private equity, real estate), trust structures, insurance, HNW wealth planning