Jersey Income Tax and MCIT: Key takeaways

Anesu Mazingaizo (CA, FMVA), Associate Director in our Funds & Corporate team, recently attended Deloitte’s seminar covering 2024 Year of Assessment tax filing trends, Economic Substance considerations, and the first wave of MCIT registrations for multinational groups.

Below is a summary of the key updates and practical implications for Jersey structures.

2024 Jersey Income Tax Returns: Key updates and filing considerations

Ongoing challenges with tax residence certificates
Obtaining Jersey tax residence certificates continues to cause delays for some taxpayers. These certificates (or alternative evidence) are essential for Jersey‑incorporated companies claiming non‑residence, and they support:

• confirming tax status to foreign authorities
• international tax treaty claims
• evidencing non‑resident status to mitigate certain tax obligations

Maintaining constructive dialogue with Revenue Jersey is advisable to minimise delays and avoid penalties.

Where certificates or supporting documents are required, early preparation remains essential. Proactive information gathering helps avoid congestion close to filing deadlines.

2025 FYE filing deadline remains unchanged
For companies with a 2025 financial year‑end, the filing deadline remains 30 November 2026. Preparing Companies financial statements within the 10‑month statutory timeframe under Jersey law is strongly recommended and best practice that is equally encouraged for limited partnerships, enabling the smooth filling of the annual tax returns.

Economic Substance: Reinforcing strong governance and on‑island activity

The seminar emphasised the ongoing requirement for clear, demonstrable compliance with Jersey’s Economic Substance regime. These rules apply to tax‑resident companies, LLCs, and partnerships conducting “relevant activities.”

To meet the criteria, entities must show they are directed and managed in Jersey, supported by:

• Board meetings held in Jersey at an appropriate frequency
• Adequate physical presence and operational expenditure in Jersey
• Skilled personnel located on the island
• Core Income Generating Activities (CIGA) performed in Jersey

Ensuring director quorum is physically met in Jersey is particularly important. Clear documentation of decision‑making and activity remains essential should Revenue Jersey review or challenge compliance.

Pillar Two rules: Awareness of new global minimum tax rules

Under Pillar Two, multinational enterprises (MNEs) with annual consolidated revenues above €750 million must achieve a minimum effective tax rate of 15% in every jurisdiction from 2024.

Where the rate falls below 15%, “top‑up” taxes may apply through either:

• the Income Inclusion Rule (IIR), or
• the Undertaxed Profits Rule (UTPR)

The seminar also highlighted the first round of Multinational corporate income tax (“MCIT”) registrations for MNE groups with December year‑ends, and the emerging registration frameworks in both Jersey and Guernsey.

Revenue Jersey (RJ) visits: Staying prepared

RJ may conduct visits where necessary. Keeping documentation, governance records, and substance evidence aligned with internal policies will help ensure smooth interactions should a review arise.

Supporting clients through an evolving tax landscape

As regulatory expectations continue to expand across Jersey and internationally, Belasko remains committed to helping clients navigate these evolving tax and substance requirements with confidence.

How else we can help you

Beyond tax matters, our funds and corporate team at Belasko is committed to supporting every dimension of our clients’ operations. Our talented specialists bring deep expertise across fund setup and structural establishment, fund closings, equalisations, capital calls and distributions, investor onboarding and KYC, governance and company secretarial services, transaction and investment support, financial reporting, and audit coordination.

We tailor our services to the unique needs of each client, delivering solutions that are intelligent, precise, and agile. Our approach is built to unlock potential, empowering you with administration that stays aligned with your strategy and anticipates your next move.

If you would like to discuss how these updates may affect your entities, or if you need assistance preparing for upcoming compliance milestones, please get in touch with the Belasko team.

We’re here to help you stay ahead.