The Corporate Tax Review was launched in 2009 following communication via Her Majesty's Treasury ('HMT') that certain members of the European Union Code of Conduct Group on Business Taxation ('CCG') no longer deemed the zero/10 regimes of the Crown Dependencies (Guernsey, Jersey and the Isle of Man) to be compliant with the 'spirit' of the Code.
The review, which included a public consultation phase, aimed to examine the options available for Guernsey and, if necessary, define a new corporate tax regime compliant with the Code but maintaining Guernsey's competitive position as a financial centre.
The review was conducted under the principle that Guernsey Corporate Tax regime must:
- be competitive;
- be internationally acceptable;
- promote a sustainable economy in Guernsey;
- be based on a simple, solid rationale (and not be over-complicated);
- give rise to other benefits such as double taxation agreements
Having committed to the review process Guernsey's corporate tax regime was not reviewed by the CCG alongside those in Jersey and the Isle of Man in 2010. However, on completion of the review of zero/10 regimes in Jersey and the Isle of Man both regimes were deemed compliant with the removal of taxation on deemed distributions. As a result Guernsey zero/ten regime was subject to review by the code of conduct group in 2012.
Following review by the code of conduct group, with effect from January 2013 Guernsey will also remove the taxation on deemed distributions. The 10% tax rate will also be extended to capture regulated insurance and fiduciaries activities. Further details are available on Page 7 of the 2013 Budget [3Mb].
The Corporate tax review was formally closed in December 2012 (see 2013 Budget [3Mb], Appendix I: Conclusion of the 2010 Corporate Tax Review, Page 41)