The £82bn ethical move: British family shifts trusts out of Guernsey to pay more UK tax
- The Royal Court of Guernsey has approved the relocation of three family trusts worth £191.9m from Guernsey to the UK to subject them to UK taxation
- Adult beneficiaries unanimously requested the change based on ethical convictions about fair tax contribution, despite substantial financial disadvantage
- Actuarial calculations show the trusts could grow to £82bn by 2134 if left offshore but will be depleted by that date if moved to the UK
- The court found moral, ethical and social benefits to beneficiaries outweighed financial detriment, with minor beneficiaries' interests secured for 100 years
- The judgment establishes that beneficiaries' ethical convictions about taxation can constitute legitimate "benefit" justifying trust variations
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The Royal Court of Guernsey has approved an unusual application to relocate three family trusts worth £191.9m from Guernsey to the UK, specifically so they can be subjected to UK taxation.
The decision represents a rare case where beneficiaries actively sought increased tax liability based on ethical and moral convictions about fair contribution to public services.
