Family office in Guernsey: licensed private trust companies, family investment funds and tax caps for resident principals

Guernsey regulates family offices through the activities they carry out rather than through a family office regime. Providing trustee, company administration or director services by way of business falls under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2020 (the Fiduciaries Law), and managing, advising on or administering investments falls under the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (the POI Law). A single-family office that only coordinates the family's own affairs, without acting as trustee or investment manager for others, may sit outside both laws, but each entity has to be analysed, and an office that serves unrelated families needs GFSC licences.

The most important recent change concerns private trust companies. From 2000 a PTC could rely on an exemption, and many argued they did not act 'by way of business'. Following its 2024 review of PTCs and ahead of the MONEYVAL evaluation, the GFSC confirmed in guidance issued on 3 September 2025 that all Guernsey PTCs and private trust foundations fall within the Fiduciaries Law. They must either hold a full fiduciary licence under section 6 or obtain a limited permission under section 3(1)(ac). A limited permission is available where the PTC acts only for a specific trust or a group of connected trusts with a common family interest, does not market itself to the public, and is administered by a Guernsey licensed fiduciary that keeps enough knowledge of its ownership and control to be satisfied it is properly governed. Permissions are generally granted for three years and the application fee is currently £1,430. Existing PTCs that previously relied on the exemption should review their position.

Trusts are governed by the Trusts (Guernsey) Law, 2007, which permits trusts without a perpetuity limit, reserved powers for settlors and non-charitable purpose trusts, and protects Guernsey trusts against foreign heirship and matrimonial claims. The Foundations (Guernsey) Law, 2012 provides a separate legal person whose charter is filed with the Registrar but not open to public inspection, while its rules are not filed at all. A foundation must have a Guernsey resident agent, usually a licensed fiduciary, and a guardian only where it has purposes without beneficiaries or beneficiaries whose rights to information are restricted. For investment pooling, Route 3 of the Private Investment Fund Rules and Guidance, 2021, in force since 22 April 2021, created the Family PIF for investors who share a family relationship or are eligible family employees. It may not be marketed or raise capital outside the family, needs no GFSC-licensed manager, and must appoint a licensed designated administrator; fiduciary licensees can now obtain a limited POI Law licence solely for this role.

Guernsey companies and foundations generally pay income tax at 0%, with higher rates for certain regulated financial services, utilities and Guernsey land and property income, and there is no capital gains, inheritance or wealth tax. Groups with consolidated revenue of EUR 750 million or more fall under the Pillar Two rules Guernsey has implemented. Resident individuals pay 20% but may elect to cap their liability; for 2026 the caps remain £160,000 on non-Guernsey income and £320,000 on worldwide income, with a £60,000 cap for new residents who pay at least £50,000 of document duty on an open market property. Housing is controlled under the Population Management (Guernsey) Law, 2016, so newcomers without local status normally buy on the open market register.