Guernsey vs Jersey
Guernsey vs Jersey
Guernsey is an established centre of excellence for international pension and savings plans, with more than 50 years’ experience. The island is politically, economically and environmentally safe and secure.
2 Guernsey vs Jersey
Constitutional, political and geographical differences
Jurisdiction Guernsey
Political position in the world
Historical ties to UK
Jersey
Constitutional, politcal and geographical differences
A self-governing jurisdiction with more than 800 years of constitutional autonomy, having split from Normandy in 1204.
A self-governing jurisdiction since 1204, with more than 800 years of constitutional autonomy.
A British Crown Dependency – relationship with the UK is through the Crown not the UK Parliament.
A British Crown Dependency – relationship with the UK is through the Crown not the UK Parliament.
Right to appeal in UK privy council
Political volatility
Application and principles of English common law
Environmentally and geographically stable
Not volatile – secure and stable with candidates typically being elected independently.
Not volatile – secure and stable with candidates typically being elected independently.
Origins based in Norman-French law, with a strong emphasis on English common law due to strong influence of UK.
✔ No major weather, geological or other environmental disasters.
Origins based in Norman-French law, with a strong emphasis on English common law due to strong influence of UK.
✔ No major weather, geological or other environmental disasters.
Regulatory and legal differences
Jurisdiction Guernsey
Regulatory and legal differences
Jersey
Principal trust legislation
Pensions are legally defined and given separate authority to trusts, under The Regulation of Fiduciaries, Administration Businesses and Company Directors etc (Bailiwick of Guernsey) law, 2000.
Pension providers are regulated under The Pension Scheme and Gratuity Scheme Rules and Guidance, 2020 (Pension Scheme Rules).
Tax approval regime contained in Income Tax (Guernsey) Law 1975.
No specific pensions legislation. Tax approval regime contained in Income Tax (Jersey) Law 1961.
Regulation of pension providers
Consumer protection
Pension scheme rules, which further enhance member protection
Fees and commission must be disclosed to pension plan members
Asset protection legislation
Yes. In 2017 Guernsey became one of the first jurisdictions in the world to regulate pension providers.
The Channel Islands Financial Ombudsman. The
Yes (introduced in 2017 and updated in 2020).
Channel Islands Financial Ombudsman.
Adherence to international standards
Jurisdiction Guernsey
Regulatory and legal differences
Jersey
EU Economic Substance status
Compliance with OECD
Compliance with FATF
Member of the International Organisation of Pension Supervisors
Financial services regulator a member of the Network for Greening the Financial System
Member of the United Nation’s Financial Centres for Sustainability
(2019).
Whitelisted (2009).
Compliant with Moneyval and fully committed to the implementation of FATF and CFT recommendations
(2009).
Compliant or largely compliant with FATF and CFT recommendations
Whitelisted
Whitelisted (2019).
Whitelisted
International standards/products
Jurisdiction Guernsey
Jersey
Product comparison - personal and corporate pensions and savings plans
Qualified Recognised Overseas Pension Scheme (QROPS) permitted
Qualifying Non-UK Pension Scheme (QNUPS) permitted
International Pension Plan/International Savings Plan permitted
Bespoke Occupational Pension Schemes
Multi-employer Occupational Schemes
Multi-member Retirement Annuity Trust Scheme
Number of pension providers/ administrators
Number of pension providers/administrators increased or decreased over past 10 years?
Yes – with non-resident members benefitting from being able to make payments without the deduction of any local witholding taxes. This further prevents double taxation.
Yes – with non-resident members benefitting from being able to make payments without the deduction of any local withholding taxes. This further prevents double taxation.
Stats and figures
Source: GFSC (Q4 2021)
Increased.
Unknown (JFSC does not keep these figures). 97*
Unknown (JFSC does not keep these figures).
