straxiom.
Corporate tax

Guernsey · Proposed legislation

Guernsey budget debate advances four tax amendments; final vote pending

Published 2 min read

On 5 November 2026, Guernsey’s States carried four amendments affecting the treatment of excess Pillar Two receipts, review of the Open Market Tax Cap, downsizing relief and possible high-value property duty changes; the overall Budget proposition remained pending.

Official document:
P.2026/82 — 2027 Budget; Amendments 6, 8, 10 and 12
Development date:
2026-11-05

Amendment 6 passed by 32 votes to two. It directs the Policy & Resources Committee to transfer to the Core Investment Reserve all Pillar Two receipts above specified forecasts for 2025–2028—£75 million, £77 million, £79 million and £74 million respectively—and 50% of receipts for 2029 and later years. The amendment concerns the use of excess receipts, not the Pillar Two tax charge.[1][5]

Tax-cap and downsizing reviews

Amendment 8 passed 32–1 and directs a cost-benefit analysis of the Open Market Tax Cap for the 2028 Budget Report. Amendment 10 passed 23–10 and says downsizing relief should not continue beyond the end of 2027. These votes set policy directions within the Budget process; they do not by themselves establish enacted eligibility or rate changes.[2][3][5]

High-value property duty

Amendment 12 passed 33–6. It directs investigation of at least a one-percentage-point increase in document duty for property transactions above £2.5 million, including a new band above £10 million, with any resulting changes prepared for the 2028 Budget. No operative rate change is claimed.[4][5]

Overall Budget remains pending

The official voting record still listed P.2026/82 among active propositions after the amendment votes. Tax teams should treat the outcomes as interim parliamentary developments and await the final proposition decision, consolidated text and any implementing legislation before changing calculations, conveyancing advice or compliance positions.[5][6]

Official sources

  1. [1] P.2026/82 Amendment 6

    States of Guernsey · Document date: 2026-11-03

    Pages 1–2: excess Pillar Two receipt transfers and forecast amounts.

  2. [2] P.2026/82 Amendment 8

    States of Guernsey · Document date: 2026-11-03

    Pages 1–2: Open Market Tax Cap cost-benefit analysis.

  3. [3] P.2026/82 Amendment 10

    States of Guernsey · Document date: 2026-11-03

    Pages 1–2: non-continuation of downsizing relief after 2027.

  4. [4] P.2026/82 Amendment 12

    States of Guernsey · Document date: 2026-11-03

    Pages 1–2: investigation of higher document duty and new high-value band.

  5. [5] States Meeting voting record

    States of Guernsey · Document date: 2026-11-05

    Finished Propositions rows at 14:15, 14:20, 15:26 and 15:47; vote tallies for Amendments 6, 8, 10 and 12; Active Propositions table.

  6. [6] P.2026/82 — 2027 Budget

    States of Guernsey · Document date: 2026-10-05

    Main proposition and linked amendment texts; parent Budget proposition status context.

Read our editorial standards or report a correction.