For most high-net-worth individuals and business owners considering a move to Jersey, tax is one of the primary factors in the decision. The differences between the UK and Jersey tax frameworks are material — but understanding them accurately, including the exit costs and ongoing obligations, is essential before making any decisions.

This article compares the two jurisdictions across the main tax categories. It does not constitute tax advice. All figures and rates are correct at the time of writing but are subject to change. You should always take independent advice from a qualified Jersey tax adviser and, where you are departing the UK, from a specialist UK-to-Jersey cross-border tax adviser.

Income Tax

United Kingdom. Income tax in the UK is charged at graduated rates: 20% (basic rate), 40% (higher rate), and 45% (additional rate on income over £125,140). Scottish residents pay different rates. National Insurance contributions add a further charge on employment and self-employment income — currently 8% for employees on earnings between £12,570 and £50,270, and 2% above that.

The effective tax rate for a UK additional rate taxpayer, including NICs, can exceed 47% on employment income.

Jersey. Income tax is charged at a flat 20% on all taxable income. There are no higher rates, no additional rates, and no equivalent of National Insurance contributions. For High Value Resident applicants, a tax cap arrangement limits maximum annual liability to £250,000 — making the effective rate on very high incomes substantially below 20%.

The difference. An individual paying 45% income tax on UK income of £2 million per year would pay approximately £900,000 in UK income tax (simplified). In Jersey, the same gross income would attract a tax liability of £400,000 at the standard 20% rate, or £250,000 under the HVR tax cap. The annual saving in this illustration is £650,000.

These are illustrative figures only and do not account for the full complexity of each tax position.

Capital Gains Tax

United Kingdom. CGT is charged at 24% on residential property gains (above the annual exempt amount) and 18% (basic rate) or 24% (higher/additional rate) on other assets. There is no annual exempt amount from April 2026 onwards. Business Asset Disposal Relief (previously Entrepreneurs’ Relief) provides a 10% rate on qualifying business disposals up to a lifetime allowance of £1 million.

For a higher rate taxpayer selling a business for £10 million, CGT at 24% after the lifetime allowance would produce a liability of approximately £2.4 million.

Jersey. There is no capital gains tax. Gains on the disposal of any asset — investments, business interests, property, art, or anything else — are not taxable in Jersey. A £10 million business sale in Jersey attracts zero CGT.

The difference. The CGT position is one of the most significant financial differences between the two jurisdictions for individuals with large investment portfolios or business interests approaching disposal.

Important caveat. Departing the UK does not immediately eliminate UK CGT exposure. The UK has anti-avoidance provisions that can apply to gains arising while the individual was UK-resident. Departure timing, asset location, and the structure of any disposal all need specialist advice. The UK’s temporary non-residence rules may also apply.

Inheritance Tax

United Kingdom. IHT is charged at 40% on the value of an estate above the nil-rate band (currently £325,000 per person, or £500,000 if the main residence is left to direct descendants). The effective rate for a large estate can make IHT one of the most significant wealth transfer costs a family faces.

Jersey. There is no inheritance tax in Jersey. Estates passing on the death of a Jersey-resident individual are not subject to inheritance tax in Jersey, regardless of the value of the estate.

The difference. For an estate worth £20 million, UK IHT at 40% (above the nil-rate band) would produce a liability of approximately £7.9 million. In Jersey, the liability would be zero.

Important caveats. The position regarding UK-situs assets — particularly UK property held by a formerly UK-domiciled individual — is complex and requires specialist advice. Domicile is a distinct concept from residence; a UK-domiciled individual who moves to Jersey may retain UK IHT exposure on worldwide assets for a period. The rules in this area changed significantly in 2025 and require careful analysis by a specialist adviser.

Stamp Duty / Land Transaction Tax

United Kingdom. Stamp Duty Land Tax (SDLT) in England applies at rates up to 12% on the purchase of residential property, with a 3% surcharge for additional properties. For a property purchased at £3.5 million, SDLT would be approximately £256,250 (standard) or £361,250 (with the surcharge).

Jersey. Jersey levies Land Transaction Tax on property purchases at rates broadly similar to UK SDLT on the headline transaction value, though the structure differs. No stamp duty equivalent applies to share transfers.

Corporate Tax

United Kingdom. The UK corporation tax rate is 25% for profits over £250,000. Small profits rate of 19% applies below £50,000, with marginal relief between the thresholds.

Jersey. The standard corporate tax rate for most trading companies in Jersey is 0%. Regulated financial services companies, utilities, and certain other sectors pay 10% or 20%. For most businesses, the 0% rate means corporate profits can be accumulated without Jersey corporate tax, subject to the substance requirements.

The difference. A business generating £5 million of annual profit would pay £1.25 million in UK corporation tax. In a Jersey-based company meeting the substance requirements, the liability would be zero.

The Exit: UK Departure Tax Considerations

Moving from the UK to Jersey is not a tax-free event. Individuals departing the UK should take specialist advice on:

Split-year treatment. In the year of departure, the individual may be UK-resident for part of the year and non-resident for the remainder. UK tax applies on worldwide income for the UK-resident part of the year.
UK income sources. UK-source income — UK rental income, dividends from UK companies, UK pension income — may remain subject to UK tax even after departure, depending on the double tax treaty position.
Temporary non-residence. The UK’s temporary non-residence rules can tax certain gains and income in the year the individual returns to the UK, if they return within five years.
Domicile. Domicile is distinct from residence. A UK-domiciled individual who moves to Jersey does not automatically lose UK domicile and may retain UK IHT exposure.

The UK-to-Jersey move requires coordinated advice from a UK tax specialist and a Jersey tax adviser. The planning should begin well before the physical move takes place.