Guernsey: Types of Company
Exempt Insurance Companies
The Income Tax (Exempt Bodies) (Guernsey) Ordinances 1989 and 1992 also cover insurance companies, called Category E bodies. Guernsey residents may not have direct shareholdings in Exempt Insurers, and the exemption does not apply to income originating in Guernsey (other than from bank deposits).
The application for exempt status has to be made annually, accompanied by various types of information. Tax due from previous years must have been paid. See Offshore Legal and Tax Regimes for details of the taxation of Exempt Insurers.
Registered insurance companies may take advantage of the Protected Cell (Guernsey) Ordinance 1997, under which multiple cells may exist within one company; the taxation basis of protected cell companies is equivalent to that of exempt companies. Protected cell company status under the 1997 Ordinance is generally reserved for authorised collective investment schemes, insurance companies and closed-ended investment companies.