Pre-MCIT registration requirements: Are you ready?

While Jersey’s enactment of the Multinational Corporate Income Tax (Jersey) Law 2025 (“MCIT”) may feel like old news already, the approaching 31 December 2025 registration deadline is bringing it back into sharp focus and with it the specific challenges that Pillar Two poses for an international financial centre such as Jersey.

Indeed, we are now seeing many clients starting to deal in earnest with the specific challenges that MCIT poses while simultaneously determining how the broader Pillar Two framework will impact the wider group. Accordingly, we have compiled the below list of questions to assist you in determining what registration obligations you might have in Jersey, if any. While the below list is not exhaustive, it does serve to highlight the most common queries we are seeing arising from the registration process and resultantly the information that your team is likely to require to complete this process.

As with all things Pillar Two and MCIT related, careful consideration may be required in advance of completing the registration form noting in particular those instances where MCIT diverges from the Pillar Two framework and indeed the instances where Pillar Two relies on definitions within local law which may vary between jurisdictions. For convenience, we have included at point 6 below, a non-exhaustive list of areas that, in our experience, are often underestimated or overlooked, and might require further consideration.

1.      Have you assessed if the MNE group is required to register for MCIT purposes?

MNE groups are required to register for MCIT (“in-scope MNE group”) if they have:

• At least one entity located in Jersey, and
• Consolidated group annual revenues of at least €750 million, in at least 2 of the 4 previous accounting periods.
• Specific consideration should here be given to whether the ‘deemed’ consolidation rule might apply in instances where the parent entity does not prepare consolidated financial statements.

2.      Have you identified which is the ultimate parent entity (“UPE”) of the MNE group?

Details of the UPE are required within the MCIT registration form, including name and address.

3.      Have you identified which is the “reporting entity” for MCIT purposes?

The “reporting entity” will be:

• The UPE of the group if located in Jersey;
• If the UPE is not located in Jersey, the only Jersey entity that is an Intermediate Parent Entity (“IPE”) of the group; or
• If neither the UPE nor the IPE are located in Jersey, the group has the option to nominate a Jersey entity within the group to act as reporting entity.

Revenue Jersey will consider and review the nomination of the reporting entity made by the group when determining the reporting entity.

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

4.      Have you determined which are the Jersey constituent entities?

An entity will be a Jersey constituent entity (in relation to an in-scope MNE group) if:

• The constituent entity is located in Jersey; and
• The constituent entity is not:
  • An investment entity,
  • An insurance investment entity, or
  • A securitization entity.

We note that the concept of “location of an entity” for MCIT purposes might be different from the concept of “tax residence” for pre-existing income tax purposes.

Dates are required when a constituent entity joined the group after 31 December 2024 or left the group in 2025.

5.      Have you obtained a Jersey tax identification number (“TIN”) for all the Jersey constituent entities, including trusts?

All Jersey entities within the group (including the reporting entity) require a tax identification number (“TIN”) in the format NNN-NNN-NNNN, attributed by Revenue Jersey.

Jersey entities without an existing TIN would need to obtain one before the MCIT registration can be made. Depending on the type of entity, the following links should be used:

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

6.      Common Pitfalls

Should any of the following scenarios strike a chord, it is likely to be advisable to obtain professional advice covering this point.

• Country-by-Country Reporting (“CBCR”) Safeharbour

While MCIT does make provision for a number of the GloBE safeharbours, not all of the GloBE safeharbours have been replicated within MCIT, in particular MCIT does not make provision for the CBCR Safeharbour.

• Substance-Based Income Exclusion (“SBIE”)

MCIT does not provide for the SBIE as contained within the GloBE Rules, this is to avoid a jurisdictional effective tax rate lower than 15%.

• Exclusion from the Under-Taxed Profits Rules (“UTPR”) of MNE Groups in the initial phase of their international activity

Please note that Jersey has not adopted the exclusion for MNE Groups within the initial phase of their international activity (i.e. those groups with operations in six or fewer jurisdictions). While the exclusion from UTPR may be available at group level, no such exclusion is available under MCIT.

• Investment Entity Tax Transparency Election

The treatment of an Investment Entity under MCIT is not fully aligned with the Pillar Two Model Rules. As such, if an MNE Group is applying this election, Jersey-specific tax advice may need to be obtained to ensure appropriate compliance and reporting.

• Location of an Entity, and particularly, a Flow-Through Entity

While the definition of a Flow Through Entity is aligned between MCIT and Pillar Two Model Rules, this is not the case when determining its ‘location’ – for MCIT purposes, the location of an Entity determines whether the Entity is a Jersey Constituent Entity. As such, Jersey-specific advice may need to be obtained in the event that an MNE Group includes Jersey Flow-Through Entities.

If you would like to discuss Jersey’s MCIT registration requirements/pre-requirements, or Jersey’s Pillar 2 implementation and how this may impact your group, please do not hesitate to contact us. 

Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.