RULE 14 QUESTIONS ASKED
As your Deputy, I use Rule 14 of the States' Rules of Procedure to ask important questions that demand transparency and accountability from our government.
Full Transparency
Every Rule 14 question I've asked
Clear Explanations
Why I asked each question and what the answers mean
Direct Sources
Links to official States responses
How to use this page
- Questions are organized chronologically (newest on top)
- Click any question to expand detailed reasoning and analysis
- Use the official response links to verify information
2025
NOVEMBER
Questions Asked
PREAMBLE
Previously under Rule 14 Question 2025-28 (https://parliament.gg/parliamentary-business/assets/questions/2025-28) I asked a series of questions in order to seek better understanding on the issue of the use of consultants by the States in formulating its tax strategy.
The States' reply contains two key claims:
- "The financial projections on the size of the structural deficit were compiled by States of Guernsey officers in the Treasury team."
- "No external consultants were engaged in the projections."
While the first claim may be technically true (Treasury officers did the final compilation), the second claim appears to be inconsistent with the available evidence.
The existence and content of the Fiscal Policy Panel (FPP)'s reports and the Deloitte report directly undermine the States' answers.
The Fiscal Policy Panel (FPP)'s Reports
The Fiscal Policy Panel (FPP) functions as an external consultancy:
- The FPP members (Prof. Matthew Agarwala, Prof. Francis Breedon, and Matthew Bell OBE) are all external, independent experts with primary employment outside the States of Guernsey.
- Their work involves detailed fiscal analysis, sustainability assessments, and specific recommendations on addressing the structural deficit - all core to the "projections" mentioned in the States' reply.
- The 2025 report continues this work, providing analysis and recommendations specifically on "permanent fiscal balance" - which is the conceptual foundation for understanding and projecting structural deficits.
The FPP's work directly involves deficit projections and analysis:
- Both reports extensively analyse the States' financial position, revenue shortfalls, and the unsustainability of current fiscal policies.
- The 2025 report contains detailed charts and analysis of the States' deficit positions under different scenarios (Fig. 24, pages 34-35), showing projected deficits with and without tax reforms.
- The Panel explicitly states that "revenues in recent years have been insufficient to support the Panel's definition of permanent fiscal balance" and that the "current tax base... cannot sustainably support both the current profile of service provision and the level of infrastructure investment needed."
The FPP's mandate covers the very subject of the structural deficit:
- The Terms of Reference in the 2025 report (Appendix 1, page 37) specifically include examining the relationship between infrastructure investment and its importance in achieving permanent fiscal balance - which is essentially the structural deficit issue.
- Their analysis of the States' reserves, debt, and investment levels directly informs understanding of the structural deficit.
The Deloitte Report
Source: The report attached to P.2021/97, Economic Impact Study of the States of Guernsey Tax Review.
Key Evidence:
- Page 2, "Important Notice": The report explicitly states it was prepared by Deloitte LLP for the States "in accordance with the contract with them dated 10 March 2021." This confirms they were engaged external consultants.
- Scope of Work: The report's purpose was not just to opine on tax options, but to analyse them in the context of the fiscal deficit. The entire report is framed by the "fiscal pressures" and the need to raise revenue to meet the "24% of GDP" target. Deloitte's analysis is inextricably linked to the deficit projections.
Key examples:
- Revenue Modelling for the Deficit Gap: The report analyses how much revenue each tax option would raise to close the deficit (see Table 7 on page 39, and the analysis on pages 39-41). Deloitte did not create the original deficit number, but they were absolutely engaged in modelling the financial projections of the solutions to that deficit.
- The Deficit is the Core Justification: The report's Executive Summary (Page 4) begins by stating the problem: "Guernsey is facing increasing fiscal pressures... the economic impacts of COVID-19 have resulted in the States operating at a deficit of £64 million." Deloitte's entire mandate was to analyse options to fix the problem defined by that deficit.
3. Public Record in the Proposition (P.2021/97)
The report was not produced in a vacuum; it was commissioned to inform a specific policy proposition. The very existence of Proposition P.2021/97, "The Tax Review Policy Letter," which proposes the tax options, is predicated on the work done by Deloitte. The Policy Letter and the Deloitte report are a packaged set of documents. It is implausible to claim that the policy response to the deficit was developed without the engagement of the consultants who produced the foundational analysis for that policy.
Based on these two documents alone, there is clear evidence that:
- External experts were indeed engaged to analyse the States' fiscal position, including structural deficit issues.
- Their work directly involved projections and analysis of the deficit situation.
- The States' claim of "no external consultants were engaged in the projections" is, in my respectful view, contradicted by the evidence of the reports produced by Deloitte and the Fiscal Policy Panel (FPP).
The distinction the States might be trying to make in its reply to Rule 14 Question 2025-28 is that Treasury officers "compiled" the final numbers, but this ignores the substantial analytical and advisory role played by Deloitte and the externally constituted Fiscal Policy Panel (FPP) in shaping the understanding and projections of the structural deficit.
QUESTIONS
- If the Fiscal Policy Panel (FPP) is not considered an external consultancy, how does P&R officially categorise it?
- Given that the members of the FPP are not States' employees and its purpose is to provide "independent commentary and analysis," can P&R clarify what the functional difference is between their role and that of a consultancy, beyond the label used?
- Given that the Deloitte report attached to P.2021/97 was produced under contract and forms the entire evidence base for the Tax Review options, on what basis does P&R assert that "no external consultants were engaged in the projections" when their work was fundamental to projecting the revenue outcomes of the proposed solutions to the deficit?
- Would P&R agree that while Treasury officers may have compiled the initial deficit figure, the extensive modelling of how to fill that deficit (including the revenue projections for GST) was in fact carried out by the external consultancy firm Deloitte and/or the FPP (whose members are non-States employees)?
- The States' website confirms that the Fiscal Policy Panel (FPP) was "commissioned by the Policy & Resources Committee in 2023." Can P&R please clarify the contractual and remuneration arrangements for the three members of the Panel?
- My previous Rule 14 question (2025-28) asked about the consultancy firm engaged "to look into the issue" of the deficit. P&R's reply focused on who "compiled" the "projections." Can P&R confirm whether any other external parties besides Deloitte and the Fiscal Policy Panel (FPP), were engaged to analyse, advise on, or model the structural deficit, even if the final numerical projections were tabulated internally?
- The Deloitte report stated that, 'This Final Report has been prepared by Deloitte LLP ("Deloitte") for the States of Guernsey (the "States") in accordance with the contract with them dated 10 March 2021 (the "Contract")'. Can P&R confirm how much in total the States paid to Deloitte for the Contract?
- Did P&R evaluate whether the required analysis could be undertaken internally before deciding to engage external advisers? If yes, please provide details. If no, why was this not the case?
- Can P&R confirm whether GST was recommended by: P&R, and/or Deloitte, and/or the FPP?
- Can P&R confirm whether P&R staff and/or Deloitte and/or the FPP modelled the closing of tax loopholes including (but not limited to): ability for shareholders to borrow tax-free money from their own companies under the guise of Commercial Loan; ability for a trust to classify distribution to beneficiaries as "capital" after a certain period of time in order to avoid paying taxes?
- Can P&R confirm whether political member(s) or officer(s) of P&R were the first to suggest engaging the three FPP members?
- Can P&R confirm whether political member(s) or officer(s) of P&R were the first to suggest engaging Deloitte?
- Can P&R confirm whether political member(s) or officer(s) of P&R signed off on the deliverables of the FPP?
- Can P&R confirm whether political member(s) or officer(s) of P&R signed off on the deliverables of Deloitte?
Why I Asked These Questions
I tabled this Rule 14 question to test the accuracy of P&R's earlier claim that "no external consultants were engaged in the projections" underpinning the GST package. Islanders deserve to know:
- whether the Fiscal Policy Panel - paid approx. £110,000 - function as de-facto consultants;
- how much public money was paid to Deloitte (£125,000) and Ernst & Young (£198,067) for tax-review work;
- whether any of those external bodies modelled, recommended or helped design the GST proposal;
- whether loophole-closing alternatives were ever put through the same external modelling;
- who inside P&R initiated, approved and signed off on each external contract;
- whether the States first tried to do the work in-house before sending fees off-island;
My Analysis of the Response
P&R's letter asserts that the GST proposals were developed entirely in-house, with no external recommendations, and that no external consultants were "engaged in the projections." However, the same document confirms the following:
- Deloitte was paid £125,000 to analyse the economic impacts of the short-listed tax options that the Tax Review Steering Group had identified and provided to them... the same short-listed options that later formed the basis of the GST proposals ultimately brought to the States.
- Ernst & Young was paid £198,067 for a corporate tax review commissioned by a States resolution. P&R note that EY did not make recommendations on GST itself, but their analysis formed part of the broader evidence base considered during Phase 2 of the Tax Review.
- The Fiscal Policy Panel (FPP) consists of three external economists whose work cost approximately £55,000 per year according to P&R - roughly £110,000 across the 2023/24 and 2024/25 periods. They were specifically tasked with assessing the sustainability of the States' fiscal position, including the deficit path and the adequacy of infrastructure investment... both central assumptions underpinning the GST-plus package.
In total, this represents £433,067 of public money spent on external workstreams operating within the same policy period in which the GST proposal was developed.
P&R assert that this external work did not influence the projections behind GST. If that is correct, then it raises an unavoidable question: if the engagements of Deloitte (£125k) and Ernst & Young (£198k) played no part in the deficit analysis, the projections, or the GST proposal, then what precisely were they commissioned to deliver?. Was their ultimate intention to provide external validation for a GST conclusion the Tax Review Steering Group had already reached?
I will leave it to islanders to judge for themselves what the nearly half-a-million pounds of fees paid to external parties are actually for.
OCTOBER
Questions Asked
- What is the name of the consultancy firm that the Committee for Economic Development has engaged to provide advice on Guernsey's finance industry and where are they primarily based?
- It was understood that the consultancy firm will be performing some survey on the island. Is that true? If yes, what exactly are they trying to find out? Please list all the items.
- What other deliverables will the consultancy firm be delivering? Please list all the items.
- How much in total will the consultancy firm be paid (or has been paid) for all the deliverables?
- What is the name of the person from the States/Committee for Economic Development who approved the engagement of the consultancy firm?
- Has the States/Committee for Economic Development at least attempted to obtain the desired deliverables using the human resources available within the States before engaging the consultancy firm? If yes, please elaborate. If no, why not?
- When will the consultancy firm's work begin (if it has not already)? And when will it conclude?
- What is the name of the person from the States/Committee for Economic Development who will be signing off on the consultancy firm's deliverables?
Why I Asked These Questions
Value-for-money test.
Guernsey is forecasting structural deficits of £66 m (2025) and £77 m (2026). Against that backdrop, every external contract must be demonstrably unavoidable. My questions were designed to establish whether the Committee had first proved that the same outputs could not be produced in-house or with cheaper, local expertise.
Transparency on scope and deliverables.
£559,300 is a significant spend on a single consultant... for such a small island as Guernsey. I wanted the public to see, line-by-line, what they are buying and how long the work will last.
Accountability for the spending decision.
By naming the approving officer and the sign-off process, I sought to ensure that responsibility rests with an identifiable elected member or senior official, not an amorphous "project group".
Competitive-process check.
Large off-island contracts can become habitual unless scrutinised. I asked who approved the engagement so that the public can judge if everything is above board and that the competitive-tender rules were followed.
Opportunity-cost reminder.
£559,300 would, for example, cover the entire annual running cost of several school programmes or fund tax relief schemes for the low-middle income earners. My questions invite members to confront that trade-off explicitly.
My Analysis of the Response
The cost-sharing defence is not a meaningful justification.
The reply notes that the States will pay "only" 62.5 % (£349,563). Even if the GFSC and Guernsey Finance pay the rest, every pound is still ultimately Guernsey money: the GFSC is funded by industry levies that licensees pass on to island consumers, and Guernsey Finance is grant-aided by the States. The total £559,300 remains a charge on the local economy.
"External credibility" is subjective at best.
The Committee justifies the spend by saying an outside name gives the final report "greater credibility". Credibility with whom? Rating agencies and international investors assess statutory data, regulation and political stability, not whose letterhead appears on a strategy document. The answer never quantifies how much extra investment or tax revenue this supposed credibility will generate, so the return on the £559,300 is wholly speculative.
No evidence of internal scoping.
The response concedes that "significant expertise" exists inside the States but asserts that "additional external expertise would be useful". Nowhere is there a costed comparison showing what could be delivered by:
- Combining the GFSC's policy team,
- The States' own economics unit, and
- Modern AI / data-analytics tools already licensed by government
In the private sector, a board would require that internal-option memo before releasing half a million pounds. The public sector should be held to the same discipline.
If time-frame is self-imposed, then the plea isn't justified.
The answer hints that an internal study would create "challenges in respect of the timeframe". If the deadline was set by the Committee itself and is not a statutory or regulatory requirement, then a self-inflicted timetable should not automatically justify a self-inflicted invoice.
Confidentiality cloak may limit island benefit.
One of the two promised deliverables will remain "confidential" and unseen by taxpayers. If the juiciest recommendations are withheld, the public will never know whether it got £559,300 worth of insight, nor hold the States to account for implementing it.
Conclusion
The Committee's answers confirm propriety but fail to demonstrate necessity. At a moment when the States is proposing GST, higher social-security contributions and the loss of Mortgage Interest Relief, approving a half-million-pound "strategy" that could plausibly be home-grown sends a signal that fiscal restraint is being preached to residents more than it is practised by committees.
Questions Asked
- What was the name of the consultancy firm that was engaged to look into the issue of the States' projected financial deficit? And where is this consultancy firm primarily based?
- What were the deliverables expected of the consultancy firm? Please list them. Were they all successfully delivered?
- Did the States/P&R at least attempt to obtain the desired deliverables (including the financial projection and modelling) using the human resources available within the States before engaging the consultancy firm? If yes, please provide details. If no, why not?
- Was the suggestion of implementing GST in Guernsey first proposed by the consultancy firm?
- It was understood that the consultancy firm was in favour of the States implementing GST. It was also understood that they modelled how GST could be the solution to the States' projected financial deficit. Did the consultancy firm modelled any other potential solutions other than GST? If yes, what are they? If no, why not?
- Did the consultancy firm model what the effects of closing various tax loopholes for the wealthy would be for the States' financial health? If yes, please provide details. If no, why not?
- If the consultancy firm believed that the money the States could gain from closing tax loopholes isn't significant enough to warrant modelling, how would they know that is the case without first modelling the scenarios? Was the believe based on any empirical Guernsey data?
- What was the name of the person from the States/P&R who approved the engagement of the consultancy firm?
- What was the name of the person from the States/P&R who signed off on the results delivered by the consultancy firm?
- When did the consultancy work begin and when did it finally conclude?
- How much was the consultancy firm paid in total for the deliverables they provided?
- Is there a publicly available link for the public to read the report generated by the consultancy firm? If yes, please provide the link. If no, why not?
Why I Asked These Questions
I tabled a Rule 14 question asking for details of any consultancy work behind the States' tax strategy figures so that the people can see...
- The names of the external parties involved in shaping Guernsey's fiscal future, so the public can judge if there is any conflict of interests
- The total amount spent on the consultations, so the public can gauge if the amount is reasonable
- Whether they are local or from the UK, to see how much public money is leaving Guernsey
- Whether the States have exhausted all internal resources before engaging the consultants, to judge if the spending was justified
- Whether the consultants played a part in GST proposal
- Whether the consultants modeled any other revenue generating measures besides GST (e.g. closing of tax loopholes for the rich)
- The names of the States' staff who engaged and signed off on the work of the consultants, for public accountability purpose
In short, I wanted islanders to see who advised the States on tax policy, how much was spent, whether local firms were used, and whether other revenue options - such as closing loopholes - were explored before GST was put on the table.
My Analysis of the Response
P&R's reply contains two bold statements:
- "The financial projections on the size of the structural deficit were compiled by States of Guernsey officers in the Treasury team."
- "No external consultants were engaged in the projections."
Those words matter, because they are the only basis the public has been given for believing that every big number in the tax debate was produced in-house.
Yet three documents already published on the States' website appear to tell a more complicated story.
1. The Fiscal Policy Panel (FPP)
Since 2020 P&R has commissioned three independent academics to sit on the FPP (you can find out who they are on the Fiscal Policy Panel page of the States' website). Their 2023 and 2025 reports analysed "permanent fiscal balance", produced deficit trajectories under different tax scenarios and warned that current policy is unsustainable. The 2025 version even charts the deficit path (Fig. 24, pages 34-35). The Panel is independent. Calling that "no external consultant" looks strained.
2. The Deloitte contract
Proposition P.2021/97 is accompanied by an "Economic Impact Study" prepared, as the report itself says, "by Deloitte LLP in accordance with the contract with them dated 10 March 2021". Deloitte modelled how each tax package would close the £64 million gap identified by Treasury. Again, the work was commissioned, paid for and formed part of the deficit arithmetic eventually presented to the States.
Treasury officials certainly "compiled" the final slide-deck, but the building-blocks came partly from outside. The distinction between "compilation" and "analysis" may satisfy a lawyer, but to the public it feels like hair-splitting.
Good policy needs good numbers... and good numbers need transparency. If P&R wants to gain islanders' trust, they should start by acknowledging every parties that helped write the sums.
Questions Asked
-
How much did the States spend on consultants for the financial year 2020, 2021, 2022, 2023 & 2024 respectively?
For the avoidance of doubt, "consultants" in this question refers to entities external to the States who provided paid advice to the States or its subsidiaries. -
For each financial year above...
- who are the consultants engaged by the States (please provide their full names), and
- where is their main business based (e.g. Guernsey or UK, etc.), and
- how much did they receive (or will be receiving) as payment for their service, and
- what exactly are they paid for (i.e. what is the subject matter of the deliverables), and
- what is the status of the deliverables (e.g. delivered, work-in-progress or not started yet)
Why I Asked These Questions
As a Deputy, I'm using my position to obtain important information for the public from the government. I recently sought details on the States' spending on consultancy to answer six key questions:
- The total amount spent on consultancy over the last five years, so the public can gauge if that amount is reasonable
- The names of the consultants, so the public can judge if everything is above board
- Whether they are local or from the UK, to see how much public money is leaving Guernsey
- What specific work the consultants were paid for, to judge if the spending was justified
- The individual fees paid, to assess if we received value for money
- Whether the work was ultimately delivered, to gauge competence
My Analysis of the Response
The public deserves greater transparency on public spending. Unfortunately, based on the response I received, it looks like we are not going to get it.