Technical article

Jersey, Guernsey and the Isle of Man: Tax Turns on Whether Any Heir Lives There

The three Crown Dependencies, Jersey, Guernsey and the Isle of Man, give a similar answer.

By Neil Solomon · 4 min read

Imagine a widow in Texas with two sons, one in Mexico and one in Spain. She is thinking about a trust run by a trustee on Jersey, and she asks a plain question. Will the island tax the trust when none of her family lives there?

The three Crown Dependencies, Jersey, Guernsey and the Isle of Man, give a similar answer. The tax mostly turns on the heirs. If no heir lives on the island, the sources say the island generally leaves the trust alone. If one heir lives there, or the person who set up the trust still lives there, the answer changes.

Jersey

A trustee who lives in Jersey is, on its face, open to Jersey income tax. With no Jersey-resident beneficiary, Carey Olsen (a law firm, tier B, 2021) says the tax office does not generally seek to tax the trustee or the beneficiaries. The standard rate is 20%. There is no capital gains tax.

The Jersey tax office has put this in writing. Its Concession M1 covers trusts with non-resident beneficiaries. A 2021 ruling (tier A) extends it to purpose trusts, which have no named beneficiaries, as long as no Jersey resident other than a local charity has or is meant to have an interest. Another ruling, from 2019, says that when a beneficiary is entitled to the income and receives it directly, the beneficiary is assessed and the trustee is not.

Guernsey

Where the settlor and every beneficiary live outside Guernsey, the trust is taxed only on income that comes from Guernsey. Bank interest from a Guernsey bank is not counted for a trust with no resident beneficiary. That comes from Carey Olsen in 2021, and an older note from 1998 says the same and adds that tax is rarely if ever payable. If the settlor lives in Guernsey and is not shut out from benefit, the income is taxed in the settlor's hands at 20%.

Isle of Man

A trust is Manx for tax if a trustee lives there or the trust is run from the island. When all beneficiaries live elsewhere, it is taxed like a non-resident individual. A 2009 article from the law firm Appleby says that means no Manx tax if all the income is foreign (approved bank interest aside) and no beneficiary is Manx. It also says trustees are not liable for capital gains tax.

Side by side

Jersey and Guernsey have no inheritance tax. Guernsey charges no stamp duty for creating a trust (1998 source).

Trust assets that a trustee holds are not part of the settlor's own estate in Jersey, so the probate fee does not reach them.

Will the trust be on a public list?

The sources say none of the three islands keeps a register of trusts. Their ownership registers cover companies. The information is held for the authorities and is not open to the public. This comes from a 2017 law-firm note, so the current rules may read a little differently.

What this touches

The trustee carries most of the paperwork. The family carries the question of who lives where. A son who moves to the island, or a settlor who comes back to it, can change the answer for the whole trust.

You might say: "A 2009 article is old." It is. The Isle of Man rule rests on that one article, and the Guernsey figures come from 1998 and 2021. The Jersey tax office rulings are the most recent and the most official. The three islands point the same way, and each island's tax office page is the place to read the current wording.

You could ask a trustee on each island three things. Who counts as a resident beneficiary? What happens if one heir moves there later? Which of their own fees apply each year?

If you have sat across a table from an island trustee, what did you wish you had asked first? Share it here. Someone else may be about to sit down in that chair.

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