The Tax Treatment of Film Production in Guernsey
Guernsey offers a favourable tax regime in which to produce films and other related media. Most
production companies and artistes working in Guernsey should be able to arrange their affairs
so that they are not liable to tax in Guernsey.
- A non-Guernsey company making a film in Guernsey will generally not be regarded as having a
taxable presence in Guernsey and hence will not be liable to tax in Guernsey on profits made from
the production or subsequent distribution of the film.
- A company incorporated in Guernsey but owned by non-Guernsey residents can enjoy the same treatment
by applying for tax exempt status. In return for a fee of £600 such a company is treated as though it is not resident in Guernsey for tax purposes and thus can enjoy
a similar freedom from taxation in Guernsey as a company incorporated elsewhere.
- If for any reason a company making a film in Guernsey wishes to be liable to tax in Guernsey
but does not want to pay tax at the standard rate of 20%, it may be able to apply for international
status. International status is available to companies that are owned by non-Guernsey residents
and which do not trade with residents of Guernsey. Such a company is able to agree a rate of taxation at a level
above 0% up to a maximum of 30%. Ordinarily, the rate agreed would be fairly nominal. Such a company is entitled to have a taxable presence in Guernsey
and may be appropriate if, for example, the company concerned wished to establish a permanent office
- Self employed artistes working in Guernsey on the production of a film will generally not be regarded as
carrying on a business in Guernsey and thus in the absence of taking up residence in Guernsey
they will not be liable to taxation in Guernsey on their earnings.
- Work performed in Guernsey by employees of a non resident production company that does not have a taxable
presence in Guernsey is regarded as part of an employment carried on outside Guernsey. Thus, provided
that the individual concerned is not treated as resident in Guernsey for tax purposes, the
remuneration from such work will not be liable to tax in Guernsey.
- Self employed artistes who are not resident in Guernsey and who work in Guernsey for less
than six months are unlikely to become liable to social security contributions in Guernsey. The
liability of employees will depend on a number of factors including whether or not they are paying equivalent
contributions in another country that has a reciprocal arrangement with Guernsey.
- There is no value added tax or other comparable indirect tax in Guernsey.
For further details on the tax treatment of companies or individuals in Guernsey please contact:
20 New Street
St Peter Port
Tel: +44 (0) 1481 721000 (Office)
Tel: +44 (0) 1481 719544 (Direct)
Telefax: +44 (0) 1481 722373
This note provides a summary of some of the key features of the tax treatment of film production companies
and artistes working in Guernsey in the production of films. It should not be relied upon to be complete
and specific advice should be sought in relation to particular arrangements.