Funds Comparison: Guernsey vs Ireland vs Mauritius

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Guernsey vs Ireland vs Mauritius

Banking Insurance Investment and Funds Private Wealth Pensions Sustainable Finance

Guernsey is compliant with Moneyval and fully committed to the implementation of FATF and CFT recommendations with respect to anti-money laundering and combating the financing of terrorism

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St. Peter Port, Guernsey Guernsey vs Ireland vs Mauritius

Guernsey Funds Framework Comparison

Jurisdiction

Description

Legal Framework

Political Position

A self-governing jurisdiction since 1204, with more than 800 years of constitutional autonomy.

Origins based in Norman-French law, with a strong emphasis on English common law due to strong influence of UK.

Secure and stable with candidates typically being elected independently (non-partisan).

A self-governing jurisdiction, based on the 1922 Constitution of the Free Irish State following Anglo-Irish Treaty. Part of the European Union.

Irish Constitution was developed following Irish independence and incorporates elements of British common law.

Secure and stable with partisan politics.

A self-governing jurisdiction following independence from United Kingdom in 1968.

Amalgamation of French civil law and British common law.

Secure and stable with partisan politics.

Ireland Legal Status
Guernsey Mauritius
The Guernsey Financial Services Commission is the competent authority responsible for the supervision of all regulated fund structures in Guernsey.
Financial Services Commission Mauritius is the competent authority responsible for the authorisation and supervision of all regulated fund structures. The Central Bank is the Irish competent authority entity responsible for authorising and for the ongoing supervision of all regulated fund structures. Products Regulator 3 guernseyfinance.com
The

Guernsey Funds Framework Comparison

Regulation D Private Placement. Regulation D Private Placement. Regulation D Private Placement. Investment Company Protected Cell Company Incorporated Cell Company Partnerships Unit Trust Investment Company Protected Cell Company Partnerships Unit Trust Investment Company Partnerships Irish Collective Asset-Management Vehicle Unit Trust Authorised Fund (Class A/B/Q) Private Investor Fund (3 routes) Manager Led Product Registered Fund National Private Placement Regime (NPPR) NPPR Professional Collective Investment Schemes Specialised Collective Investment Schemes Expert Funds Self-Managed Schemes NPPR NPPR Undertakings for Collective Investment in Transferable Securities (Money Market Funds and Exchange Traded Funds) Alternative Investment Fund (Qualifying Investor AIF and Retail Investor AIF) Option of Passporting and NPPR NPPR Guernsey Mauritius Ireland Types of Structures Example Types of Schemes Market Access to EU Market Access to UK Market Access to US 4 Guernsey
Ireland
Mauritius
vs
vs

Guernsey Funds Framework Comparison

ESG Credentials Taxation

Fees

Can elect to register as a Guernsey Green Fund.

Founding Member of United Nations’ FC4S network.

Options to list on the Sustainable segment of The International Stock Exchange.

Application Fee - £3,500.

Additional £500 for fast track.

Annual Fee - £3,500.

Fees are the same regardless of fund structure.

Managers are subject to separate charge.

Adherence to tax neutrality, no capital gains tax.

Requirement for funds in scope to meet Sustainability Disclosure Requirements from 2021.

Minimum €6,320 (Approx. £5,300) and additional fee for sub-funds.

No fees for registration.

Managers are subject to separate charge.

Tax exempt on income and gains for payments received from funds if they fall within relevant categories.

Application fee - USD1,000 (Approx. £750) for first fund/additional for each additional fund.

Annual Fee – USD3,000 (Approx. £2,200) for first fund/additional fee for additional fund.

Managers are subject to separate charge.

Adherence to tax neutrality, no capital gains tax.

N/A
Guernsey Mauritius
5 guernseyfinance.com
Ireland

Guernsey Funds Framework Comparison

Listing Opportunities

EU Economic Substance Status

Compliance with OECD Framework

Compliance with FATF Mutual Elevations

Tax Reporting

Guernsey Mauritius

Proven diverse options to list on The International Stock Exchange, London Stock Exchange, Euronext, NYSE and NASDAQ.

Ireland

Options to list on the Irish Stock Exchange, London Stock Exchange, Euronext, NYSE and NASDAQ.

Adherence to International Standards

(2019)

Compliant

Compliant with Moneyval and fully committed to the implementation of FATF and CFT recommendations

Most funds opt to list on the Stock Exchange of Mauritius.

N/A

Adopters of FATCA/CRS Compliant

Compliant or largely compliant with FATF and CFT recommendations

Adopters of FATCA/CRS

Adopters of FATCA/CRS Compliant

Exited grey list (2021) following review.

Whitelisted Whitelisted (2019)
6 Guernsey
vs Ireland vs Mauritius

Guernsey has an AA- credit rating from Standard & Poor’s, representing the island’s ‘very strong’ capacity to meet its financial commitments

7 guernseyfinance.com
Fort Saumarez, Guernsey
Please recycle me 70% of the wood used in creating this brochure is recycled material, with the remaining 30% from a ‘controlled/sustainable’ wood forest Somers House, Rue du Pre, St Peter Port, Guernsey GY1 1LU +44(0) 1481 720 071 info@guernseyfinance.com

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