Prepare Guernsey property document-duty working papers for 2026 conveyances, including graduated rates, the repealed additional-property surcharge, conditional downsizing relief and transaction evidence. Use for document duty, property purchase costs, realty versus personalty and the 2025 surcharge transition. This source-cited draft covers the island of Guernsey and does not extend these rates to Alderney or Sark. It supplies recomputable examples using established chargeable realty values, not a valuation opinion. The new statutory extension supplies ordinary charging/valuation, named exemption gates, indirect-transfer self-assessment/payment and appeal methods, checked in the fresh whole-pack review. Complex valuations, relief claim administration and title advice remain separate requirements. Retain the transaction date, official source version and advocate's classification before relying on a calculation.
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| Chargeable realty slice | Rate |
|---|---|
| First £300,000 | 2.25% |
| Above £300,000 to £500,000 | 3.50% |
| Above £500,000 to £950,000 | 4.00% |
| Above £950,000 to £1,250,000 | 4.25% |
| Above £1,250,000 to £2,500,000 | 4.50% |
| Above £2,500,000 to £5,000,000 | 5.50% |
| Above £5,000,000 | 7.00% |
Source-cited draft. Independent source review is recorded in the pack README; professional attestation remains pending. This is a working-paper calculation, not authority to complete a conveyance or make payment.
This Guide covers ordinary realty conveyance calculations in the island of Guernsey using the current-rate table in the official response dated 21 May 2026. The 2025 amendment ordinances expressly have effect in Guernsey; do not transplant these calculations to Alderney, Sark or another territory. 2025 amendment ordinances, section 3 of each.
The Royal Court describes duty on prescribed documents presented to it, with transaction-dependent rates, fixed amounts and exemptions. The legal library now provides the current charging Laws and Rates Ordinances used below. Earlier HTTP 403 receipts are historical, not a current availability blocker. The new statutory extension is checked in the fresh ordinary-method whole-pack review; the previous published review covers its predecessor. Direct charging Law; indirect charging Law.
Apply each rate to the slice of established chargeable realty value within the band, then add the slices. The official response distinguishes realty from personalty excluded from its duty dataset and gives examples confirming graduated treatment. Do not automatically deduct 2.5% of the price for contents: establish the actual supportable allocation. Official response, question 11, Tables 1 and 3 and explanatory text.
| Chargeable realty slice | Rate |
|---|---|
| First £300,000 | 2.25% |
| Above £300,000 to £500,000 | 3.50% |
| Above £500,000 to £950,000 | 4.00% |
| Above £950,000 to £1,250,000 | 4.25% |
| Above £1,250,000 to £2,500,000 | 4.50% |
| Above £2,500,000 to £5,000,000 | 5.50% |
| Above £5,000,000 | 7.00% |
Source: 21 May 2026 official response, Table 1. Table 2 in the same document models a proposed 15% band, not the current schedule. Do not use it as the operative rate table. The existing 2026 schedule must also be checked against any later enactment at the transaction date.
Working-paper sequence:
Direct acquisition or secured charge. Document Duty Law section 2 covers acquisition of an interest in Guernsey real property and a charge registered in the specified mortgage/obligation records; a partage is expressly included before exemption tests. Section 1 prevents registration of the relevant document unless duty is paid to the Greffier or the transaction is exempt. The liable person is the person by or on whose behalf the document is to be registered; do not assume that every party has identical liability under this Law. Direct Law ss1–2.
Value before bands. For an arm's-length transaction, section 6 uses total consideration; otherwise it uses market value of the real property transferred. Money's-worth consideration is valued at its market value. Even where arm's length and good faith are asserted, section 6(3) permits the Greffier to deem the transaction otherwise than at arm's length if the stated consideration is inadequate. Foreign-currency consideration is converted to Guernsey currency at the rate on the registration date. Reconcile realty/personalty, every element of consideration and valuation evidence before applying the bands. Section 5 requires the joint consideration/market-value declaration, the grounds for exemption and arm's-length treatment, and full and frank disclosure. Direct Law ss5–6.
The current Direct Rates Ordinance s1 independently confirms every graduated rate above. Its section 2 sets 0.00% of the sum secured for a non-exempt registered charge within the charging Law's section 2(1)(b); that does not set conveyance duty or cancel Court/registration fees. An established non-exempt, non-arm's-length acquisition with £600,000 stated consideration and £900,000 market value therefore uses £900,000: £6,750 + £7,000 + £16,000 = £29,750, rather than £17,750 on the lower consideration. These assumptions do not override an actual exemption or establish the valuation. Supplementary control.
Exemptions are conditions, not labels. Direct Law section 3 identifies the following routes; retain the documents proving the precise statutory limb:
Sources: Direct Law ss3–4. The Greffier's section 10 avoidance-adjustment power applies to the effect of a transaction or series, with the statute's broad arrangement/action/omission scope; do not treat an artificial series or an overseas step as outside that screen merely because its paperwork is labelled exempt.
The 2025 rates amendment repeals section 1A and paragraph 1C(a) of the 2017 Rates Ordinance; the companion anti-avoidance rates amendment repeals its section 1A and removes the stated section 1A cross-reference. The Budget identifies these changes as removal of the additional 2% for properties not intended as the purchaser's principal private residence. Hansard records approval of each ordinance on 5 November 2025, and each section 5 provides commencement on the day made. Do not automatically add the former surcharge to a 2026 calculation. Ordinances and Budget paragraph 5.92; Hansard pages 63–65, budget propositions 12 and 13.
Section 2 of each amendment provides transitional relief for qualifying registrations in the period beginning 7 October 2025 and ending on commencement. The relief is a payment equal to the difference between duty actually paid and duty that would have applied had section 1 already operated. Keep registration date, duty receipt and recalculation. The claim form, processing route and any claim deadline have not been verified; do not invent a deadline or treat an accounting entry as a refund received. Both amendment ordinances, section 2.
The Budget describes relief at 0% on the first £500,000, maximum saving £13,750, continued through the end of 2026. Conditions described include at least 25% reduction in domestic-building TRP rating; the sold property being the vendor's principal private residence for the preceding two years; and one use per individual and per property sold. A jointly owned sale does not create relief for both replacement purchases. Obtain the full operative rules and claim evidence before accepting eligibility. Budget paragraphs 5.95–5.96 and footnote 16.
The operative test is the decrease in assessable units of plan area, using the statutory TRP definitions, not a percentage fall in price or in the cash TRP bill. Direct Rates Ordinance s1B(2), (4). Do not subtract £500,000 and restart the ordinary rate bands on the balance; qualifying relief zeros the specified first slices. The current Rates Ordinance supplies the additional ordinary gates: the statutory domestic-property references, replacement acquisition for principal private residence, sale of the previous principal private residence held as such for at least two years, and at least 25% fewer assessable units of plan area. Direct section 1B(3) prevents a second use by the person and use for a replacement acquisition by another former owner once the qualifying relief has already been assessed. Direct relief does not apply where registration is on or after 1 January 2027. The acquirer's section 1C(b) declaration must address eligibility and both repeat-use limits. The actual guidance/claim administration still needs its transaction-specific check. Direct Rates Ordinance ss1B–1C.
For an indirect relevant transaction, the companion Rates Ordinance has its own section 1B conditions and limits: the repeat-use limb refers to another former occupier, and the expiry is execution on or after 1 January 2027, not direct-document registration. Do not interchange those gates. Indirect Rates Ordinance s1B.
Consolidation discrepancy: the Direct Rates consolidation still prints section 1C(a), though the adopted 2025 amendment expressly repeals it; the indirect consolidation notes also misstate the 2025 repeal's effective year as 2024. Use the actual 2025 amendments and adopted 5 November 2025 date already evidenced above. Those editorial errors do not revive the additional-property surcharge. The consolidations themselves disclaim authoritative legal effect. Preserve the conflicting texts in the source record rather than silently normalising them.
Assume established chargeable realty of £600,000, no exemption and no additional charge. Ordinary duty is £6,750 + £7,000 + £4,000 = £17,750. If all downsizing conditions are separately established, the first £500,000 relief saves £13,750, leaving £4,000. The calculation does not establish eligibility. Rate table; downsizing terms.
name: Guernsey 600000 realty ordinary and qualified downsizing
inputs:
realty: 600000
steps:
- first_slice: 300000 * 0.0225
- second_slice: 200000 * 0.035
- third_slice: (realty - 500000) * 0.04
- ordinary_duty: first_slice + second_slice + third_slice
- qualified_relief: first_slice + second_slice
- qualified_net_duty: ordinary_duty - qualified_relief
expected:
ordinary_duty: 17750
qualified_relief: 13750
qualified_net_duty: 4000
At established chargeable realty of £6 million, with no relief, duty is £308,250, matching the official response's Table 3. Charging 7% on the whole value would be wrong. Official response, Tables 1 and 3.
name: Guernsey six million realty official cross-check
inputs:
realty: 6000000
steps:
- band1: 300000 * 0.0225
- band2: 200000 * 0.035
- band3: 450000 * 0.04
- band4: 300000 * 0.0425
- band5: 1250000 * 0.045
- band6: 2500000 * 0.055
- band7: (realty - 5000000) * 0.07
- duty: band1 + band2 + band3 + band4 + band5 + band6 + band7
expected:
duty: 308250
Without relief, £500,000 chargeable realty produces £13,750. An additional £100 is charged at 4%, adding £4; it does not reprice the earlier slices. These examples use whole-pound results and do not determine statutory fractional-pound rounding. Official rate table.
Supplementary regression control retained byte-exact.
HM Greffier registers property transactions, assesses document duty and collects it as agent for the States. The Registry also collects applicable Court fees; these are separate from the duty bands above. Route assessment and collection questions through the Greffe/transaction advocate rather than assuming the income-tax return process applies. Royal Court, Conveyances and Bonds.
The Court describes a conveyance as a deed transferring land title. It must be prepared by an Advocate and presented in the Contracts Court; the published ordinary schedule is Tuesday or Thursday morning. Confirm the actual sitting and representation arrangements with the advocate. The page does not establish an unconditional right to complete on either day or settle power-of-attorney requirements. Royal Court, Conveyances.
The Contracts Court witnesses conveyances, real-property agreements and bonds before public registration. Each document is witnessed by the presiding Lieutenant-Bailiff and two Jurats. A calculated duty amount alone therefore does not prove that the deed has been witnessed or registered. Contracts Court procedure.
Suggested completion file:
| Evidence | Purpose |
|---|---|
| Advocate-prepared deed, parties and representation instructions | Identify the actual conveyance and authorised participants |
| Chargeable-value reconciliation and duty calculation | Explain the amount submitted for assessment |
| Duty and Court-fee entries separately reconciled to receipts | Avoid describing all completion costs as tax |
| Witnessed deed and registration confirmation | Establish completion of the Court/Registry stages |
| Relief decision or claim correspondence | Distinguish eligibility asserted, accepted and money actually repaid |
This is a recommended evidence file, not a prescribed filing form. The sources establish the institutional process; they do not establish every submission cut-off, payer obligation, payment method or penalty.
The Budget's anti-avoidance-duty explanation expressly includes indirect transfers through property-company shares. Obtain the share transaction documents and underlying property/ownership details before deciding which regime applies. Do not treat unchanged registered land title as proof of no duty. 2026 Budget, glossary: Anti-Avoidance Duty.
The current Anti-Avoidance Law now supplies the ordinary route. Section 1 requires consideration in money or money's worth conferring a significant benefit relating to Guernsey real property, where direct document duty is not payable. Significant benefit includes rights/opportunities to occupy or control occupation, receive/direct rent or other proceeds, or enjoy/control enjoyment. Transfers through company shares, guarantees, foundations, trust expectations or partnerships can qualify; absence of Guernsey residence, incorporation or physical presence does not itself avoid the charge. Indirect Law s1(1)–(3), (6)–(7).
First run the section 1(4) exclusions: the listed succession/court-order, lease/licence, servitude/wayleave/covenant, recognised-exchange shares, unchanged-beneficial-owner nominee transfer, collective-investment, unexercised option, bona fide loan-security and arm's-length property-management circumstances. Exercise of an option is separately capable of conferring the benefit. Then run section 2's actual exemption tests: the defined family transaction, specified transferee status, fully-owned company/group routes, qualifying unchanged-economic-share partnership reorganisations, and the active-business company/partnership property routes. The latter expressly exclude using the property for letting for money or money's worth; a rental property company's trade label alone does not satisfy that exemption. Indirect Law ss1(4),2–3.
For a non-exempt relevant transaction, section 4 uses the market value of the significant benefit at the transaction date. The separate Indirect Rates Ordinance s1 supplies the same graduated percentages as the direct table, applied to this different statutory base. Obtain the actual benefit valuation and rights/ownership evidence. Do not mechanically substitute the share price, gross property value, percentage shareholding or company value net of borrowing for that valuation. For a separately established non-exempt benefit worth £600,000, ordinary indirect duty is £17,750; the 2026 non-exempt registration fee is £158, so the two identified items total £17,908 before other costs. For a relevant transaction actually exempt under the Law, duty is nil but its prescribed registration fee is £79 and its filing duties remain. Indirect Law ss4–5; 2025 Fees Regulations rr1,4, effective 1 January 2026; supplementary controls.
For direct duty, sections 1 and 5 require payment or established exemption before registration and the stated declarations, with the advocate/Court workflow above. Section 7's appeal is within 28 days immediately following the Greffier's decision, requires lodging the amount the Greffier says is payable at the Greffe, and service of a summons stating grounds/material facts. A direct transaction is not routed through the indirect 28-day self-assessment rule merely because both regimes concern property. Direct Law ss1,5,7.
For an indirect relevant transaction, transferor and transferee are jointly and severally responsible under section 5. Within 28 days of the transaction, supply the Greffier the transaction description/supporting documents, significant-benefit value unless exemption claimed, duty calculation/payment, prescribed fee, exemption grounds where claimed, and the joint complete/accurate declaration. The Greffier can require further information within 60 days after receiving the return. The current fees are £158 non-exempt, £79 exempt and £7 for copies of a register entry. Do not postpone the return merely because no share transfer is publicly registered. Indirect Law s5; 2025 Fees Regulations r1.
On referral under sections 6–7 the Director can assess the stated failure, inaccurate declaration/calculation or invalid exemption, with the written assessment identifying duty, any penalty, reasons and appeal right. Section 9 permits a penalty up to 100% of assessed duty, recoverable with unpaid duty as a civil debt; it is not automatically 100%. Section 11 requires a court appeal by summons stating grounds/material facts within 28 days immediately following the assessment date. Court suspension/modification pending appeal requires an application and court terms; an appeal is not shown to stop collection automatically. Indirect Law ss6–11.
False/deceptive or materially misleading declarations/documents and the stated knowing/reckless withholding cases are separate offences under Direct Law section 8: summary maximum six months' imprisonment or a level-5 fine or both; indictment maximum five years or a fine or both. This Guide does not convert the fine-scale level to an unverified currency amount. Case-specific criminal exposure and the complete court rules require local legal review. Do not import corporate income-tax penalties into document duty. Direct Law s8.
A property-company share transaction requires the separate anti-avoidance regime: repeal of its additional-rate provision does not repeal its charging law. Gifts, inheritances, trusts, group transfers, partial interests and exemptions need their own statutory analysis. This Guide also excludes annual property taxes, rental income tax, capital-gains treatment and conveyancing/title advice. Their absence here is not evidence of an exemption.
Obtain the island/address, legal owners and buyer, instrument and transaction dates, consideration/valuations, realty/personalty evidence, connected-party relationships, residence use and any earlier relief claims. For downsizing, obtain both TRP records and principal-residence history.
Deliver the band calculation, relief assessment, source copies, unresolved legal questions and completion/payment reconciliation. Record the exact revision independently reviewed. Do not mark the property topic or country complete from this draft alone.
| Primary source | Read date of original source review |
|---|---|
| Royal Court conveyances, duty assessment and collection, conveyance preparation, Contracts Court, document duty overview | 2026-10-22 |
| Official 21 May 2026 response, question 11, Tables 1–3 | 2026-10-22 |
| 2026 Budget and 2025 duty-amendment ordinances | 2026-10-22 |
| 5 November 2025 Hansard, pp63–65 | 2026-10-22 |
| Direct Document Duty Law v.0011 | 2026-10-28: ss1–8,10 and targeted definitions; complete operative charging/base/exemption and ordinary appeal provisions read | | Indirect Anti-Avoidance Law v.0014 | 2026-10-28: ss1–7,9,11 and targeted s18 definitions; relevant transaction, benefit/date valuation, exemptions, filing/payment, penalty and appeal | | Direct Rates Ordinance and Indirect Rates Ordinance | 2026-10-28: complete operative sections; consolidation errors checked against the already adopted 2025 amendments | | GSI127/2025 indirect-transfer Fees Regulations | 2026-10-28: complete instrument; amount/commencement page also rendered and visually checked |
Original source receipts and scoped independent review are preserved. Not yet confirmed: transaction-specific significant-benefit valuation and complex exemption evidence; detailed prescribed direct submission/relief-claim administration, 2025 transition refund processing/deadline, complete current court rules and criminal fine-scale currency amounts. Annual property taxes, rental/capital-gains tax and title advice remain outside this Guide. The new ordinary direct/indirect statutory methods are checked in the fresh ordinary-method whole-pack review. The earlier whole-pack review accepts the published revision at 6ae8c8a2, not this subsequent extension; professional attestation remains pending.
General tax and accounting reference material. A qualified local professional must verify the current law, transaction facts and filing/payment requirements before anyone acts. No professional attestation is claimed.
Contributed by Michael Cutajar.
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