Family Office in Guernsey: Rules, Costs and Tax in 2026

How is a family office licensed in Guernsey?

Guernsey has no licence or registration specific to family offices. Under sections 1 and 2 of the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 (the Fiduciaries Law), regulated activities such as forming, managing or administering trusts, companies and foundations and executorship, carried on 'by way of business' in or from the Bailiwick, need a GFSC fiduciary licence, and the GFSC says a Guernsey or Alderney company needs a full licence to carry them on by way of business from anywhere in the world. The GFSC's Guidance on Private Trust Companies (September 2025) says PTCs fall within the Fiduciaries Law and should apply for a licence under section 6 or a limited permission under section 3(1)(ac), and that it is open to consider applications for a limited permission from private trust foundations; Collas Crill (11 November 2025) reports that PTCs not acting by way of business were previously outside the Law. A family can also hold investments through a Family PIF registered by the GFSC under the Private Investment Fund Rules and Guidance, 2025 (in force 19 May 2025), which must have a designated administrator (rule 3.1); the GFSC says a fiduciary firm cannot administer a Family PIF without a licence under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (POI Law), and since 15 October 2025 a firm licensed solely under the Fiduciaries Law can apply for a limited POI licence to act as designated administrator of Family PIFs. No GFSC or States of Guernsey source was found that says whether a single family office managing only its own family's assets needs a GFSC licence or registration, including anti-money laundering registration, and the Fiduciaries Law's definition of 'by way of business' could not be read. [1, 2, 3, 4, 11, 12]

What is the minimum wealth for a family office in Guernsey?

No minimum family wealth in the GFSC's criteria for a PTC limited permission (Guidance on Private Trust Companies, September 2025) or in the Family PIF criteria in Schedule 1, Part B of the PIF Rules and Guidance, 2025: they turn on the trusts served and on family relationships, not on assets. Eligible employees who invest in a Family PIF must meet the Qualifying Private Investor definition, whose tests include an initial investment of at least USD 100,000 (or equivalent) or a net worth (alone or with a spouse or civil partner) above USD 1 million excluding the principal residence; these apply to the employee, not to the family. [1, 3]

Compare: Family Office Minimum Net Worth by Country

Who counts as family?

No legal definition of a family office family applies, because there is no family office regime. All investors in a Family PIF must 'share a family relationship, or be an eligible employee of the family', and it cannot be marketed outside the family group (PIF Rules 2025, Schedule 1, Part B); the Rules do not define 'family', so its ordinary meaning applies (rule 6.1(1)), and the GFSC says eligible employees include employees of a family office structure. A PTC limited permission is available only to a PTC that acts as trustee of a specific trust or a group of connected trusts 'with common interest, such as trusts for one family' and does not market its services to the public. The Fiduciaries Law also exempts acting as director of a company more than half owned by the director, a close relative of the director or trustees of a trust for either (section 3(1)(d)). [1, 3, 4, 11]

Can one office serve several families?

No dedicated multi-family office licence was found. An office that provides trust, company or foundation services to other families by way of business needs a full fiduciary licence under section 6 of the Fiduciaries Law, and carrying on regulated activities without one is an offence (section 1(3)); under the GFSC fee regulations in force from 1 January 2026, a primary fiduciary licence costs GBP 3,205 to apply for and from GBP 7,110 a year (fiduciary turnover of GBP 249,999 or less) up to GBP 76,075 (GBP 16 million or more). The Revenue Service's Statement of Practice C57 describes investment management services as those provided by a person licensed to carry on controlled investment business under the POI Law; the POI Law's licensing scope was not read. A firm licensed solely under the Fiduciaries Law can apply for the limited POI licence (annual fee GBP 1,000) to act as designated administrator of Family PIFs. [4, 11, 13, 14]

Which law and courts apply?

The Bailiwick of Guernsey has its own laws: the States of Deliberation set amounts such as the tax caps, and the GFSC supervises financial services under laws including the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 and the Protection of Investors (Bailiwick of Guernsey) Law, 2020. Collas Crill says disputed claims to Guernsey immovable property must be brought in the Royal Court of Guernsey and that Guernsey, Alderney and Sark each have their own succession laws; the Fiduciaries Law refers to the Court of Appeal (Guernsey) Law, 1961. No official description of the legal system's origins, of appeals to the Privy Council or of the language of the courts was opened. [4, 10, 11, 15]

Reported by the sources named, not confirmed by an official source.

What substance is required?

No substance rule specific to family offices was found. For accounting periods after 1 January 2019, Guernsey tax-resident companies carrying on specified activities (banking, insurance, shipping, fund management, financing and leasing, headquarters, distribution and service centres, pure equity holding companies and intellectual property) must show sufficient substance in Guernsey (Revenue Service); Carey Olsen reported in 2022 that acting as trustee is not in itself an activity in scope and that the rules do not apply to foundations. A PTC or private trust foundation with a limited permission must be administered by a company licensed under the Fiduciaries Law and, as a standard condition, operate within that fiduciary's AML/CFT/CPF controls (GFSC). [1, 5, 16, 17]

Which holding vehicles are available?

Companies under the Companies (Guernsey) Law, 2008, which can act as private trust companies (limited by shares or by guarantee, per Carey Olsen); protected cell and incorporated cell companies (the GFSC's written consent is needed to incorporate one, even if it will not carry out regulated activities); limited partnerships and limited liability partnerships (Ogier); foundations under the Foundations (Guernsey) Law, 2012 (in force 8 January 2013), registered with the Guernsey Registry, with a council of at least two councillors and a guardian where the Law or the charter requires one, and in which the founder has no interest merely by endowing it; trusts under the Trusts (Guernsey) Law, 2007 (Collas Crill); and Family PIFs registered with the GFSC. The GFSC will consider a limited permission for a private trust foundation that acts as trustee. [1, 2, 3, 15, 17, 18, 19, 20]

What is the corporate tax rate?

The standard rate of company income tax is 0%. The 10% rate applies to income from activities including banking, domestic insurance, fiduciary business, administration of controlled investments, custody services, investment management services to individual clients, and operating an investment exchange or an aviation registry; 20% applies to income from activities including trading regulated by CICRA, importing or supplying gas or hydrocarbon oil, large retail businesses with taxable profits above GBP 500,000, and Guernsey land and buildings (Revenue Service). Under Statement of Practice C57, the 10% investment management rate covers only services by a person licensed for controlled investment business to individual clients (natural persons, partnerships, trustees or companies), while services to collective investment schemes stay at 0%. Budget 2026 says Pillar Two applies at an effective rate of 15% to the world's largest multinational groups, and in October 2026 the States approved extending the 10% rate from 1 January 2027 (see family_office_tax). [5, 7, 14, 21]

Are there tax incentives for family offices?

No tax regime specific to family offices was found in the Revenue Service's company tax guidance or in Budget 2026; Carey Olsen says the 0% standard rate applies to most Guernsey tax-resident companies. The 2026 Tax Reform Package (published 8 June 2026), which the States of Deliberation approved in October 2026, extends the 10% company rate from 1 January 2027 to full profits of companies rather than specified activities (the package refers to regulated businesses) and to certain prescribed businesses such as accountants and legal firms, with Guernsey land and buildings income staying at 20% (gov.gg). How this applies to a PTC or a family office company was not stated, and the implementing legislation was not checked. [5, 7, 16, 21, 22]

Is there personal income tax?

Resident individuals pay income tax at a flat 20%; for 2026 the personal allowance is GBP 15,200, withdrawn by GBP 1 for every GBP 5 of income above GBP 85,000. For 2026 an individual can elect to cap tax on non-Guernsey source income (and Guernsey bank interest) at GBP 160,000, or on worldwide income at GBP 320,000 (Guernsey land and property income excluded); a new resident not resident in the previous three years who pays at least GBP 50,000 in document duty on an Open Market Part A property, bought within 12 months before or after taking up residence, can cap tax at GBP 60,000 a year for the year of arrival and the next three years (Revenue Service, Budget 2026). From 1 January 2026 a 'resident only' individual can pay a GBP 50,000 standard charge instead of tax on non-Guernsey income (Budget 2026, Carey Olsen). There is no capital gains tax; under the 2026 Tax Reform Package, approved by the States in October 2026, a 15% rate will apply to income up to GBP 28,000 from 1 January 2029, and a 3% goods and services tax (GST) will start in the first quarter of 2029 (gov.gg). [6, 7, 8, 10, 16, 21, 23]

Compare: Countries With No Personal Income Tax

Is there inheritance or estate tax?

There is no inheritance tax, estate duty or capital transfer tax, and no capital gains tax, according to the States of Guernsey; the States guide names no gift tax, and Carey Olsen (October 2025) says there is none. Mourant (27 February 2026) and Carey Olsen (May 2024) report Probate Registry fees on the gross value of the personal (movable) estate, worldwide on a first grant in Guernsey and Guernsey assets only after a foreign grant (Guernsey real estate is not counted): GBP 150 for an estate up to GBP 50,000, GBP 225 up to GBP 80,000, then GBP 50 for each further GBP 10,000 or part, with the fee capped at GBP 250,000 (Mourant: for estates above GBP 50,030,000); Collas Crill (2022) puts the fee at about 0.36% of the estate. None of them mentions an exemption for spouses or children, and no duty on inherited Guernsey real estate was found. [8, 15, 24, 25, 26, 27, 28]

Reported by the sources named, not confirmed by an official source.

Compare: Inheritance Tax by Country

How do wills and succession work?

The Inheritance (Guernsey) Law, 2011, in force since 2 April 2012, abolished forced heirship, so a person can leave Guernsey real estate, and worldwide movable estate if domiciled in Guernsey, to whomever they choose, subject to claims for reasonable financial provision (Collas Crill, Mourant, Carey Olsen). A spouse or civil partner, a former spouse or civil partner who has not remarried or re-partnered, a cohabitant of at least two years, a child, a person treated as a child of the family or a person maintained by the deceased can claim within six months of death (Mourant, 2017). Movables follow the law of the deceased's domicile and Guernsey real estate follows Guernsey law, and section 14(3) of the Trusts Law says no Guernsey trust is invalid because it defeats rights under foreign heirship laws (Collas Crill). [15, 29, 30]

Reported by the sources named, not confirmed by an official source.

Can the family get residence?

No investor visa or wealthy-person residence programme was found: the States of Guernsey's immigration page (updated 1 September 2026) and visa guidance (updated November 2024) list routes such as employment permits, Entrepreneur, UK Ancestry, family routes and the EU Settlement Scheme, and no investment amount. Under population management rules 'Anyone can live in the Open Market' (about 1,600 Part A private family homes): the owner or lessee of a Part A home can hold an Open Market Resident Certificate (up to 99 years, renewable indefinitely, GBP 50 application fee), and immediate and extended family members can live with them under Open Market Family Member Resident Permits; Open Market time usually does not count towards a Local Market residential qualification. People who are not British or Irish also need valid immigration status (gov.gg); Carey Olsen (October 2025) says British and Irish citizens and EU Settlement Scheme holders with pre-settled or settled status can live and work without a visa. The Open Market tax cap of GBP 60,000 a year for four years needs at least GBP 50,000 of document duty, which Locate Guernsey says equates to a property of GBP 1.4 million or more. [9, 10, 24, 31, 32, 33, 34]

Compare: Residency by Investment by Country

How long does set-up take?

Not found in official sources.

What are the official fees?

Indicative, from the Financial Services Commission (Fees and Administrative Penalties) Regulations, 2025, in force from 1 January 2026: a limited permission under section 3(1)(ac) of the Fiduciaries Law (as used by a PTC or private trust foundation) costs GBP 1,475 to apply for (GBP 660 for an individual), with no annual fee listed; a private investment fund (PIF) costs GBP 1,500 to apply for and GBP 1,000 a year; a primary fiduciary licence costs GBP 3,205 to apply for and from GBP 7,110 a year. The GFSC set a reduced annual fee of GBP 1,000 for the limited POI licence for designated administrators of Family PIFs (15 October 2025). There is no family office licence fee; Guernsey Registry fees for companies and foundations were not checked. [4, 12, 13, 35]

Does a private trust company need a licence in Guernsey?

Since the Guernsey Financial Services Commission (GFSC) amended its Guidance on Private Trust Companies in September 2025 (announced 3 September 2025), a PTC falls within the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) Law, 2020 and must either hold a fiduciary licence under section 6 or obtain a limited permission from the GFSC under section 3(1)(ac). The GFSC considers a limited permission where the PTC acts only as trustee of a specific trust or a group of connected trusts with a common interest, such as trusts for one family, does not advertise or market its services to the public in any way, and is administered by a company licensed under the Fiduciaries Law that confirms it will keep enough knowledge of the PTC's ownership, control and activities to be satisfied that it is effectively governed and complies with the law, and where the GFSC has no concerns about the people, parties or activities involved. A permission generally lasts three years and can be renewed, and the GFSC is open to limited permissions for private trust foundations on similar criteria. Collas Crill (November 2025) and Bedell Cristin (October 2025) report that PTCs previously relied on not acting 'by way of business' or on a discretionary exemption, and Collas Crill says the limited permission is substantially similar to that exemption. [1, 12, 36, 37]

Who supervises it, and what must it file?

The Guernsey Financial Services Commission (GFSC), which grants the limited permission. The PTC applies through the GFSC's online Application Portal and pays the fee; a separate fee applies if a name permission is also requested (the guidance cites the rules on names such as 'trust' or 'trustee' in the Financial Services Business (Enforcement Powers) (Bailiwick of Guernsey) Law, 2020), and Collas Crill reports that 'PTC' may be used freely but 'trust' or 'trustee' in the name needs a separate application. Renewal terms are set in the GFSC's grant letter, and generally no new application is needed if the information given has not changed. [1, 12]

What local requirements apply?

The PTC must be administered by a company licensed under the Fiduciaries Law, whose oversight may be shown through a director on the PTC's board, a company secretary, an authorised signatory or a combination of these. The licensed fiduciary must monitor the PTC in line with its money laundering, terrorist financing and proliferation financing risks, with enhanced monitoring and oversight because the GFSC regards the arrangement as higher risk, and keep records available for GFSC inspection; as a standard condition, the PTC must be administered within the licensed fiduciary's AML/CFT/CPF controls. Bedell Cristin adds that the fiduciary should hold beneficial ownership, director and controller, and trust party information for the GFSC on request, and Carey Olsen (2022) says acting as trustee is not in itself an activity in scope of the economic substance rules. [1, 17, 37]

What are the official fees?

Under the Financial Services Commission (Fees and Administrative Penalties) Regulations, 2025, in force from 1 January 2026, a limited permission under section 3(1)(ac) of the Fiduciaries Law costs GBP 1,475 to apply for, with no annual fee listed. Collas Crill (November 2025) gave GBP 1,420 for 2025 and reports that renewal with nothing changed needs only a written request and no fee, while a material change needs a new application and fee. A PTC that takes a full fiduciary licence instead pays GBP 3,205 to apply and from GBP 7,110 a year. The fee for a name permission was not confirmed. [12, 13]