# Guernsey corporate tax, distributions and substance v0.1

> **Source-cited draft.** Professional review is pending. Figures are limited to the periods and assumptions below. This Guide prepares working papers; it is not authority to file or pay.

## Scope

Prepare calendar-year 2026 corporate tax classification and compliance working papers. This draft does not calculate Pillar Two, regulated-sector special rules, exemption applications or every company-law obligation.

Sources were accessed on 22 October 2026. A dated rate table controls its stated period; an undated guidance page does not prove that all later amendments have been incorporated.

## Rates and activity mapping

Revenue Service publishes standard 0%, intermediate 10% and higher 20% rates. The intermediate categories include specified financial/fiduciary, custody, fund administration, investment, compliance and aviation-registry activities. Higher-rate categories include regulated trading, hydrocarbon/gas supply, large retail above the stated £500,000 taxable-profit threshold, Guernsey property income/development and specified cannabis/controlled-drug business. Classify the income stream, not merely the entity's name. [Company guidance, income tax rates](https://gov.gg/RevenueService/Companies).

The published tax-reform programme describes changes from 2027, including prescribed professional services. Do not backdate them to 2026 or assume a policy announcement alone establishes the final enacted scope. [Reform timetable](https://gov.gg/taxreform).

## Computation

1. Confirm the company's residence, accounting period, legal form, ownership and activities.
2. Build a transaction-supported bridge from accounting profit to each taxable income stream. Record source and deduction decisions separately.
3. Apply the established rate to each stream; isolate regulated or special categories for review.
4. Compute distributions and qualifying-loan liabilities separately from company profit tax.
5. Reconcile the return and certified accounts to payments and the bookkeeping ledger.

**Rate illustration:** established ordinary taxable income £100,000 at 0% produces £0 corporate income tax; separately established Guernsey rental taxable income £20,000 at 20% produces £4,000. This does not waive returns, distribution tax, substance obligations or minimum-tax review. Do not use this split if a rule requires the company's wider profit base to be taxed at another rate.

## Returns and accounts

The **2025 company return is due 30 November 2026**. Annual online filing and accountant-certified accounts are required; audit exemption does not itself remove tax certification. Use the correct return certificate and retain the qualification/authority of the certifying accountant. [Company guidance](https://gov.gg/RevenueService/Companies).

## Substance and cross-border distributions

Screen the relevant activities and document direction/management, people, premises, expenditure and local core income-generating activities. Pure equity holding and high-risk IP require their own tests. [Economic substance guidance](https://gov.gg/economicsubstance).

A distribution from income taxed below 20% to a Guernsey-resident beneficial member requires a separate tax/reporting calculation. Keep evidence of non-residence before treating a payment to a non-resident member as outside the stated distribution charge. Loans are not automatically exempt alternatives. [Company distributions and qualifying loans](https://gov.gg/RevenueService/Companies).

## Review exclusions

This is not a company-incorporation checklist, document-duty calculation, treaty-rate opinion or Pillar Two determination. Complete the entity-specific registration, ownership, audit, accounts and sector requirements separately before the country is marked covered.

## Self-checks and output

- Retain the relevant source version, the applicable period and the facts establishing scope.
- Reconcile every input to the client's records; keep estimates separate from actual amounts.
- Recompute the example and boundary cases before applying the method.
- Record exclusions and unresolved points explicitly. Do not convert a missing source into an exemption.
- Deliver a calculation, evidence list, filing calendar and reviewer questions. Record the exact revision reviewed.

## Disclaimer

General tax and accounting reference material only. These drafts have not been professionally attested. A qualified professional in the relevant jurisdiction must check the facts, current law, elections and deadlines before anyone files, pays or acts on an output.

> Contributed by Ryan Duguid.