After years of Green Papers, Billets, rejected amendments, and deferred decisions, the States of Deliberation are again being asked to vote on a substantive, costed tax reform package. The Policy Letter published this week is the culmination of over a decade of deliberation, and whatever you think of the conclusions, it is a serious piece of work that deserves a serious read.
So let me try to give you that.
The Problem They’re Trying to Solve
The starting point is not in dispute. Guernsey has been running a structural deficit for several years — spending has consistently outpaced revenue, and reserves have been used to paper over the gap. The 2026 Budget estimate puts the structural deficit at around £77 million a year, and that figure is calculated after factoring in the expected £40 million annual uplift from Pillar 2.
That £77 million is not a rounding error. It is not going to be fixed by efficiency savings alone. The General Revenue Reserve, the buffer that has been absorbing shortfalls, is projected to be exhausted by 2031 on the current trajectory.
The demographic picture makes this worse. The working age population is shrinking relative to the overall population. Three quarters of all States revenue comes from individuals, personal income tax and social security contributions. That tax base is narrowing as it ages, just as demand for health, long-term care and pension expenditure accelerates. The Policy Letter is honest about this: these pressures will continue to grow for several more decades.
This is the genuine context for what follows. You can disagree with the solution without ignoring the underlying problem.
What the Package Actually Contains
The proposed package has five main components. Here is what each actually does.
1. Income Tax: Lower Rate, Lower Threshold
The headline change is a reduction in the basic rate of personal income tax from 20% to 15%, applied to income up to £28,000. Income above that threshold continues at 20%. The personal allowance also rises by £600.
This sounds like a tax cut, and for most earners it is. But the design matters. The 15% band cuts off at £28,000 which is below the median full-time earnings figure in Guernsey. The policy is deliberately redistributive: lower and middle earners gain more than higher earners in percentage terms.
The net revenue impact is a reduction of £28 million. The income tax reform is not a revenue-raiser, it is the redistributive counterweight to GST.
2. Social Security: A Restructured System
The social security changes are more complex and have been significantly moderated from the November 2024 package. Key changes include:
- A new social security allowance for employed and self-employed contributors, set at £11,122 (currently the allowance for non-employed contributors), with a longer-term ambition to align this with the income tax personal allowance
- Employer contributions increasing to 7.6% by 2029 (phased from the current 7.1%), payable up to the Upper Earnings Limit of £196,560
- A new additional rate of 2.5% for employers and self-employed individuals on earnings between the Upper Earnings Limit and £300,000
- Employee contributions rising to 8.5% from 2028; self-employed to 14.5%; non-employed under pension age to 8.5%; non-employed over pension age to 4%
One significant change from November 2024: the proposal to apply social security contributions to all income (including rental income) has been deferred. The Policy Letter is candid about why: concern that this would push landlords out of the market, compounding Guernsey’s already serious housing supply problem.
The net revenue impact of the social security changes is a gain of £2 million.
3. Transport: Fuel Duty Down, Annual Vehicle Tax Up
This is a package of changes rather than a single measure. Fuel duty drops by 25%, broadly bringing Guernsey into line with Jersey, an estimated saving of £130–£140 per vehicle per year for private motorists.
In exchange, a new annual vehicle tax is introduced, covering petrol, diesel, hybrid and electric vehicles, based on weight and emissions. The range is £25 to £280 for private vehicles, with a median charge of around £132.
A surcharge is also added to first registration duty for private vehicles valued over £50,000 (starting at £2,500).
The net revenue gain from transport changes is £7 million. The fuel duty cut is the headline that will get the press coverage; the annual vehicle tax is the structural change that matters for the long term, particularly as electrification reduces fuel duty receipts over time.
4. GST: 3%, From 2028
This is the most controversial element, and the one that has dominated debate for years. The proposal is a Goods and Services Tax at 3%, to be introduced from 2028.
This is a reduction from the 5% that was agreed in November 2024, driven by concern about the inflationary impact. At 3%, the modelling suggests a one-off increase in RPIX of around 1.9% at introduction — down from 3.2% under the previous 5% proposal.
The GST package includes:
- Uprating of the States Pension, income support and other benefits to cover the increased cost of living, with those increases introduced ahead of the GST
- An Essential Costs Relief Payment for those on lower incomes not in receipt of income support
- An International Services Entities (ISE) scheme, mirroring Jersey’s, allowing finance businesses with international clients to pay a fee for an End User Relief Certificate rather than filing full GST returns. Expected to raise £10–12 million annually
- A commitment not to increase the GST rate before the 2030 assurance review
The net revenue gain from consumption tax measures is £55 million, the dominant revenue line in the package.
A two-thirds majority requirement to increase the GST rate in future will also be introduced, providing a structural protection against rate creep.
5. Corporate Tax: Modest Adjustments Only
The headline finding from the Tax Review Sub-Committee, chaired by Deputy Charles Parkinson and including three international tax experts, is that fundamental corporate tax reform is not recommended at this time.
The Sub-Committee considered five options, including a move to a territorial tax regime and a shift from Zero-10 to Zero-15. Both were rejected. A territorial regime would trigger a full review by the EU Code Group, take 12–18 months to resolve, and carry significant risk of business relocation. Moving unilaterally to Zero-15 was modelled to produce minimal net revenue gain once behavioural responses are factored in.
What is recommended is a set of targeted adjustments:
- Extending the 10% intermediate rate to apply to the full profits of regulated businesses (not just the regulated activity), aligning with Jersey’s approach (estimated yield: £0.5 million)
- Extending the 10% rate to prescribed businesses — accountants, legal firms, estate agents registered with the GFSC (estimated yield: up to £2 million)
- Modest increases to Guernsey Registry fees (estimated yield: ~£0.5 million at RPIX +5%)
- Further extension to construction and retail deferred until 2030 at earliest
The net corporate tax gain in the package is £6 million.
The Sub-Committee also recommends that P&R opens discussions with Jersey and the Isle of Man about a coordinated move to Zero-15 after their General Elections this year — an interesting recommendation that could be significant if picked up.
The Numbers in Total
| Measure | Net Revenue Impact |
|---|---|
| Income tax changes | -£28m |
| Social security changes | +£2m |
| Transport taxes | +£7m |
| GST + ISE scheme | +£55m |
| Corporate tax adjustments | +£6m |
| Spending efficiency savings | +£20m |
| Total | ~£62m |
Against a structural deficit modelled at £77 million, this package does not fully close the gap. The Policy Letter acknowledges this. That is precisely why the assurance review in 2030 matters, and why the commitment not to raise GST before that review carries real weight.
What This Package Is, and What It Isn’t
The political debate will focus on GST. That is understandable as it is the largest single revenue line, and it affects everyone. But framing this as simply “introducing a tax on food and goods” misses the architecture of the package.
The income tax reduction to 15% is not an afterthought. For a single earner on £28,000, the saving on income tax alone exceeds the estimated annual cost of GST on their consumption. The benefit and pension uprating is front-loaded, it happens before GST is introduced, not after. The Essential Costs Relief Payment is targeted at those not already captured by income support.
The distributional analysis in the Policy Letter shows that lower and middle income households are, on average, expected to be better off under the full package than they are now. Higher income households are expected to be modestly worse off. That is a deliberate policy choice.
Whether you accept that analysis depends on whether you trust the modelling, the mitigations, and the political commitment to hold the rate at 3%. Those are legitimate questions.
What I Think
The structural deficit is real. The demographic challenge is real. The reserves position is serious. Anyone who believes Guernsey can grow its way out of this problem without broadening the tax base is not engaging with the numbers.
The balance struck here, lower income tax rates for lower earners, a modest consumption tax, restructured social security, and restrained corporate tax changes, is a considered one. It is not the package I would have designed from scratch, and there are elements I would push back on. But it is a serious response to a serious problem, with a genuine attempt at a progressive tax approach.
The question the States must now answer is whether they agree. After twelve years of review, the question is no longer whether to act, it is whether this is the right way to act.
I’ll be watching the debate closely.
Jon Bond is Founder and CEO of Evans Bond Limited, an accountancy and advisory practice in Guernsey, and principal of Melius Consulting Limited – a business consultancy. He is also a non-executive chairman of CI Co-op and NED at Sark Shipping. The views expressed here are his own.


