Pillar Two - Jersey Update

The Multinational Corporate Income Tax (“MCIT”) regime in Jersey, effective from 1 January 2025, requires in-scope multinational enterprise (“MNE”) groups to register with Revenue Jersey.

Revenue Jersey has announced that its MCIT Registration function is now live. The interactive online form can be found here: MCIT registration information.

For in-scope MNE groups registration is a key first step, and understanding the requirements and procedures is essential to complete the process efficiently. The below provides a brief overview of the requirements and practical points to consider.

MNE groups are required to register for MCIT – an in-scope MNE group – if:

• At least one entity is located in Jersey, and
• Consolidated annual revenues of the MNE group are at least €750 million, in at least 2 of the 4 previous fiscal years.

Registration must be completed before the end of the first fiscal year in which the group is an in-scope MNE group. 

For example: a group with an accounting period from 1 January to 31 December, meeting the requirements of point 1. above, needs to register before 31 December 2025. 

The in-scope MNE group can be registered either by:

• The group's “reporting entity” or
• The group's tax agent specifically appointed to deal with its MCIT obligations.

Agents to be appointed for MCIT purposes can be different from those appointed for corporate income tax, GST and employment tax matters. While there is no standard template for an agent authority letter, certain mandatory information will be included by the agent. 

The “reporting entity” will be:

• The ultimate parent entity (“UPE”) of the group if the UPE is located in Jersey;
• If the UPE is not located in Jersey, the only entity located in Jersey that is an Intermediate Parent Entity (“IPE”) of the group; or
• If neither the UPE nor the IPE are located in Jersey or there is more than one IPE located in Jersey, the group can nominate a Jersey located entity of the group to act as the “reporting entity”.

Revenue Jersey reserves the right to review any nomination of the “reporting entity” made by the group.

When the registration form is prepared by the IPE, at the moment the form requires to indicate whether the IPE is required to apply the income inclusion rule (“IIR”) in Jersey.

The Jersey constituent entities of the in-scope MNE group will need to be listed within the form, either manually (up to 25 entities) or via uploading a .csv file (up to 999 constituent entities).

All Jersey constituent entities within the group (including the “reporting entity”) require a Jersey tax identification number (“TIN”) in the format NNN-NNN-NNNN. Jersey constituent entities without an existing TIN would need to obtain one before the MCIT registration can be completed. Depending on the type of entity, the following links can be used to obtain a TIN:

• Corporates
• Foreign companies
• Partnerships
• To obtain the TIN for a trust, an email should be sent to the Trusts Mailbox at RJTrusts@gov.je

Dates are required to be entered when a constituent entity joined or left the group during the fiscal year. Any changes to the registration details after the initial registration is submitted shall be made via email to the Pillar Two mailbox of Revenue Jersey: Pillar2@gov.je.

Revenue Jersey has published a series of FAQs to assist with the MCIT registration process, which can be found here: Easy reference questions and answers for MCIT registrations. An MCIT registration checklist, outlining the information that must be included in the form, is provided below.

If you would like to discuss Jersey’s MCIT registration requirements, or Jersey’s Pillar Two implementation and how this may impact your group, please do not hesitate to contact us. 

✅ Tax Identification Number (TIN) in the format NNN-NNN-NNNN for each Jersey constituent entity within the group

✅ Dates any Jersey constituent entity joined or left the group (since the start of the fiscal year in which the group is an in-scope MNE group)

✅ Registered name and address of the “reporting entity”

✅ Registered name and address of the ultimate parent entity

✅ Start and end dates of the group's accounting period

✅ Contact details (name and email) for at least one individual or team

✅ Letter of authority appointing a tax agent (if applicable)

✅ Tax agent's name, address, and email (if applicable)