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Tax policy reflections on OECD Pillars 1 and 2

The OECD two-pillar solution

The Organisation for Economic Co-operation and Development (OECD) and G20 are updating international tax laws to reflect the increasing digitalisation and globalisation of businesses.

Political agreement on an OECD two-pillar solution was agreed in October 2021 with 137 countries, including Jersey. This two-pillar initiative will address the tax challenges arising from the digitalising economy.

The initiative only applies to the largest multinational groups (MNEs) and therefore most entities doing business in Jersey will not see any changes to their corporate tax position.

Pillar One

Pillar One concerns only the very largest MNEs with an annual global turnover exceeding €20 billion. This pillar will reallocate certain profits of in-scope groups to countries where the group’s customers are located. Pillar One is a minimum standard that Jersey will be required to implement as a signatory of the OECD Inclusive Framework's October 2021 statement.

There will be an exclusion from Pillar 1 for regulated financial services.

Pillar Two

Pillar Two has 2 elements:

  • a double taxation treaty based rule referred to as the Subject to Tax Rule (STTR)
  • the Global Anti-Base Erosion (GloBE) rule which introduces a minimum effective rate of tax for MNEs in scope of GloBE

In scope MNEs will include only those with global annual revenue greater than €750 million. GloBE is not a Minimum Standard but a Common Approach.

OECD Pillar Two Model Rules and Commentary on OECD website

Tax policy reflections

The Government of Jersey has issued a policy paper which aims to:

  • inform international stakeholders of our serious study of the issues presented by Pillars One and Two
  • provide a description of viable policy options under consideration for which feedback is requested
  • give assurance of the government's intention for any final outcome to deliver a continuation of Jersey's fundamental commitment to offering certainty and simplicity to industry

Our aim is for Jersey to remain a competitive place to do business.

OECD Pillars 1 and 2: tax policy reflections

Jersey’s 10 key principles on the OECD two-pillar initiative

Submit your comments

You can submit your comments on the questions outlined in the reflection paper by email to TRY Tax Policy, with the subject line 'Input on the OECD two-pillars'.

Your comments should be received by 30 June 2022.

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