AFR Advocates


Guernsey: 17 October 2013 - Notice of Guernsey Disclosure Facility

This notice is to inform you of a recent agreement between the States of Guernsey and HM Revenue & Customs (“HMRC”) to establish a Guernsey Disclosure Facility (“GDP”).

About the GDF

The GDF provides an opportunity for “relevant persons” with assets or investments held in Guernsey to regularise their UK tax affairs with HMRC.

Who does this facility apply to?

A “relevant person” is defined as:

(i)             a natural person resident in the UK for UK tax purposes between 6 April 1999 and 31 December 2013; or

(ii)            a legal person incorporated in the UK or resident in the UK for UK tax purposes between 1 April 1999 and 31 December 2013,

who has had a beneficial interest in “relevant property” during such period of time. “Relevant property” is widely defined and includes Guernsey bank accounts, annuity contracts, interests in companies, partnerships, etc.

The GDF is not available to certain persons, such as those who are already under investigation by HMRC as at 6 April 2013.

When is this facility available?

The GDF runs from 6 April 2013 until 30 September 2016

Action you may need to take

This notice is purely for information only purposes. It is not intended to imply that your tax affairs are in need of remediation and that you therefore need to take some form of action. However, if you think this facility may be relevant to you, you should seek independent tax advice and obtain further guidance on the operation of the GDF.

Further information, including the full Memorandum of Understanding and Frequently Asked Questions, is available from the HMRC website, Alternatively you can contact HMRC’s “GDF Helpdesk” on 0845 6006407.