Guernsey Disclosure Facility – GDF
Related: States Of Guernsey Press Release 15th March 2013
A few days ago we tweeted that any agreement between the UK and Guernsey would contain a disclosure facility similar to the Manx DF. Today we awoke to media reports that the UK and Guernsey are “poised to conclude a deal” containing… a disclosure facility!
Of course, we did cheat as our sources had already informed us that such a conclusion was likely.
Details are scant but it appears that the GDF will be modeled upon the IoMDF (MDF). We blogged about the MDF here so we won’t repeat the detail.
Any agreement struck in principle will need to be ratified by the States of Guernsey.
It appears the genesis of these DFs lies in the UK’s unique political relationship with all three islands (Guernsey, Jersey and IoM). This is an interesting topic in and of itself which we may be minded to blog about at a later date.
For now it suffices to say that, in order to stay competitive, the Islands need to sign up to US FATCA. The UK represents the Crown Dependencies in international matters and so has an element of leverage which it appears to have used to extract these DFs from the IoM and now, it appears, Guernsey.
Jersey is currently consulting on its next move – we’ll be watching that space closely.
Today’s FT report quoted a figure of £4.2 bn of UK related “retail and trust deposits” in Guernsey. It’s not clear what the latter refers to but it is worth remembering that Guernsey went to automatic exchange of information on interest payments in 2011 and so HMRC are already informed of any interest income arising on Guernsey bank accounts belonging to UK residents.
This DF is aimed therefore at those who need to regularise their affairs from past years. We anticipate the DF will only seek to go back as far as 1999.
Email bezhan@mdaviesassociates.com with any queries or comments.