Technical article

Jersey, Guernsey and Cayman Side by Side: Fees, Setup and the Rules for Keeping Control

Three names come up: Jersey, Guernsey and the Cayman Islands.

By Neil Solomon · 4 min read

Picture a retired couple with US$2 million who want a trust on an island with a long record. These are example figures. Three names come up: Jersey, Guernsey and the Cayman Islands. They ask how the three compare on fees, on setup and on how much say they could keep over the investments.

Fees and setup

Each figure comes from a trustee's published schedule. Jersey and Guernsey setup and reporting figures are from one firm's 2026 schedules. The Guernsey low end is another firm's schedule from 1 January 2024. The Cayman schedule is dated December 2014.

A legal-guide site says a percentage model of 0.4% to 1.5% exists in Jersey but is rare. Guernsey adds a 4% surcharge on administration fees for phone, post and printing.

Keeping control

Each place lets the person who creates the trust keep some powers. The lists differ.

Jersey, Article 9A, in the statute itself: the settlor may direct the trustee on buying, keeping and selling trust property, appoint or remove trustees, enforcers and beneficiaries, appoint or remove an investment manager or adviser, change the governing law, or require the settlor's consent. A trustee who acts on such a power is not in breach of trust.

Guernsey, section 15, as a law firm described it in December 2015: reserved powers are allowed, and investment directions are covered. The settlor's power to appoint an investment manager or adviser is limited to a professional person. The author calls that inconsistent with the personal nature of the power.

Cayman, section 14, as a law firm described it in 2023: the settlor may keep eight kinds of power. These include binding directions on buying, holding or selling trust property, and appointing or removing trustees, protectors or beneficiaries. A trustee who complies with a valid exercise is not treated as in breach. Cayman also has Star trusts, which can exclude or restrict the trustee's usual duties on prudence and diversification. Only enforcers, not beneficiaries, can enforce one unless the trust says otherwise, and the trustee must include a Cayman licensed or private trust company.

What a US citizen adds

For a US citizen all three places are foreign. Creating or funding a foreign trust means filing Form 3520 with the tax return. The penalty is the greater of US$10,000 or 35% of the property sent to the trust. A secrecy law in the foreign country is not a reasonable cause.

Who this touches

You are the one keeping or giving up the powers. Your partner and children live with the deed after you step back. A professional-only rule for naming an investment manager, as in Guernsey, limits that role to professionals.

The objection

You might say the lowest schedule is the one to pick. The fixed minimums mean that at US$2 million the trustee fee is a small share of the money. A bigger difference may be the powers you can keep, which may matter more than a few hundred dollars a year.

A few doors

You could ask each trustee for its current schedule, since two of these are older. You could read Article 9A, section 15 and section 14 against the powers you want to keep.

What power would you most want to keep, and who would you trust with the rest? Share it here, and someone may benefit from your story.

Figures are estimates for planning, based on public data. Date read: October 2026.