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Foreign companies

​What is a foreign company?

A foreign company is a company which is incorporated anywhere other than in Jersey.

There are two types of foreign companies:

  • those that are managed and controlled in Jersey with directors and board meetings held in Jersey. These companies are treated as resident in Jersey and are subject to tax on all their income
  • those that are trading through a permanent establishment in Jersey only.  These companies are not treated as resident in Jersey and are only subject to tax in respect of the income from the Jersey branch

Both types of foreign companies are required to comply with all aspects of the Income Tax (Jersey) Law 1961 including the submission of tax returns.  You can read the Income Tax Law on Jersey Law website

Requesting a tax residency certificate

Foreign companies treated as tax resident in Jersey, may need to provide evidence of this to third parties, such as the Revenue Authority of another country. Revenue Jersey can supply tax residency certificates on request.

To request a tax residency certificate, please download, complete and return this form.

Certificate of Tax Residency Request

If you need multiple certificates you can email us for a 'bulk' request form.

Email Revenue Jersey 

Submitting a tax return for a foreign company

A foreign company can submit a tax return either:

  • by completing a tax return on its own behalf
  • through a trust company service provider as part of a global tax return for foreign companies (GRFIC), subject to certain conditions being met

Submitting a tax return on its own behalf

To submit a tax return, a foreign company must:

  1. tell us when the company either becomes managed and controlled in Jersey or begins trading through a permanent establishment in the Island.  We'll issue a tax reference number which is needed for online registration
  2. register on the Taxes Office Online Services
  3. submit a tax return

Global tax return for foreign companies ("GRFIC")

A GRFIC may only be submitted by a trust company service provider who is registered with the Jersey Financial Services Commission ("the Commission") to carry on trust company business.

For a foreign company to be included on the GRFIC, the foreign company must not fall into any of the categories below:

  • has / will have an individual resident in Jersey ultimately owning more than 2% of the ordinary share capital of the company at any time during the year of assessment
  • is in receipt of any rental income derived from land or property in Jersey
  • is involved in the development of land or property in Jersey
  • is in receipt of income from quarrying in Jersey
  • is in receipt of income from the importation and/or supply of hydrocarbon oil
  • is a financial services company with a permanent establishment in Jersey subject to tax at the 10% tax rate
  • is a utility company subject to tax at the 20% tax rate
  • is a large corporate retailer
  • carries on trading activities through a permanent establishment in Jersey.

If a foreign company fits any of the categories above, the foreign company will need to submit a tax return on its own behalf.

A foreign company ultimately owned by non-residents through a Jersey resident nominee (company / trust) can be included on the global tax return if all other relevant criteria are fulfilled.

Information required in a global return

The information required to be declared in respect of each company is:

  • the name of the company
  • the place in which the company is incorporated
  • the date on which the company is first managed and controlled from Jersey
  • the date on which the company ceased to be managed and controlled from Jersey (where applicable)
  • the activity of the company (activity definitions are below)
  • the accounting profit or loss

Economic substance: Relevant activities

The relevant activities are defined within the Draft Taxation (Companies – Economic Substance)(Jersey) Law 201- .

Draft Taxation (Companies - Economic Substance) (Jersey) Law 201-

Where a company is carrying on more than one category of relevant activity and the descriptions do not give guidance as to the appropriate activity to select, then you should select the activity which the company predominantly carries on unless this includes high risk intellectual property holding in which case you should select "intellectual property holding (high risk)".

Banking business

Any company which has a banking licence from the Jersey Financial Services Commission ("the JFSC").

Insurance business

Any insurance company with a permit under category A or category B (this does not include insurance brokers).

Fund management business

Any business which is regulated by the JFSC in respect of managing a fund or any business managing a fund which would be regulated by JFSC but for the fact the fund is not a public fund.

Finance and leasing business

Any business which has an activity of providing any amount of credit or financial leasing to any other person, with the intention of receiving consideration in return.

Where a company is also carrying on banking, insurance or fund management activities then select those categories of activity rather than finance and leasing business.

Headquarters business

Any activity where a company advises on or controls material risks of a connected business, or provides senior management, usually in return for management fees.

Where a company is also carrying on banking business, insurance business, finance and leasing business or intellectual property holding business select one of those categories of activity rather than headquarter business.

Shipping business

Activities involving the operation of ships outside of Jersey's waters, except where the ship is a fishing vessel, pleasure craft or small ship.

Holding company business

Any company which is the parent of other group companies where such holdings is its primary business and does not conduct other commercial activities.

Intellectual property holding business (other)

Is the business of holding of intellectual property and earning income from licence fees, royalties or similar. If the company's activities are within the description of high risk intellectual holding business then select 'intellectual property holding business (high risk)'.

Intellectual property holding business (high risk)

Is the business of holding intellectual property where the company is not carrying on research and development or distribution activities in Jersey, or the intellectual property was acquired from a connected party and subsequently leased or similar to a connected party.

Distribution and service centre business

Is the business of either purchasing of goods etc. from a foreign connected party and then the resale of the same goods, or the provision of services to a foreign connected party as its business.

Where a company carries on distribution and service centre business and another category of 'relevant activity' then select the other category of activity.

None of the above

If the company does not carry on any of the categories of relevant activity included in sub-section 1 then select 'none of the above'.  This will take you to sub-section 2 'Nature of activities (other)'.

Nature of activities (other)

Where a company is not carrying on a relevant activity then the company should select one of the other categories of activity.

Select the appropriate activity if the company met the applicable definition at any time during the financial period(s) which ends in the year of assessment.

Where a company is carrying on more than one category of activity then select the activity which is predominantly carried on by the company in the financial period(s) which end in the year of assessment.

Trading - trading through a permanent establishment in Jersey

Trading companies include all companies that are not investment holding, non-income producing asset holding or dormant companies (see below).

Trading companies that carry on an active business of, for example, buying or manufacturing goods for the sole purpose of selling the goods to third parties, typically independent persons. They also include companies that provide a service, such as provision of advice or staff to third parties. Companies that predominantly provide services (e.g. management services, treasury services) to connected parties / entities within the same corporate group should select trading –group services company.

A permanent establishment includes a branch of the company, a factory, shop, workshop, quarry or a building site, and a place of management of the company, but the fact that the directors of a company regularly meet in Jersey shall not, of itself, make their meeting place a permanent establishment.  A company which has an undertaking in Jersey (within the definition of Article 25 of the Control of Housing and Work (Jersey) Law 2012) / obtained a license from the Population Office would be regarded as having a permanent establishment in Jersey. 

Companies engaged in property development in Jersey should also be included in this category.

For the avoidance of doubt, holding companies of trading companies should not report their activity as trading but rather as investment holding.

Trading – group services company

A company that predominantly provided services (e.g. management services, treasury services) to connected parties/entities within the same corporate group. For the avoidance of doubt it is irrelevant whether the company has a permanent establishment in Jersey. All group services companies should be included in this category.

Trading – other

A company that is a trading company as described above but has not carried out any of that trading activity through a permanent establishment in Jersey and does not fall within the category trading- group service company.

Investment holding

A company that does not carry on a trade, nor fall to be non-income producing asset holding or dormant in accordance with the definitions below.

These companies typically hold assets such as equities, real property and debt receivables and receive the following types of income:

  • dividends and other similar distributions from shares, securities, stock, bonds, unit trust, and other similar investment instruments
  • interest and income equivalent to interest, including amounts received in lieu of interest
  • rental income and other forms of funds from holding real estate

Retirement annuity companies approved under Art 131B of the Income Tax Law should be included in this category.

Non-income producing asset holding company

A company holding assets with no intention of exploiting those assets for short term income, profit or gain.

An example would be ownership of property where there is no intention of letting that property for income, developing the property or disposing of the property as part of a trade. Share transfer property holding companies would select this option.

Dormant

A company which has no significant accounting transactions and is not within definition of non-income producing asset holding. Significant transactions do not include:

  • filing fees paid to the Jersey Financial Services Commission
  • penalties for late filing of a tax return
  • consideration received on the issuance of shares

Global tax return submission

The global return must be submitted by 31 December in the year following the year of assessment.

The GRFIC will no longer be available from 2020 (2019 company return).

Complete GRFIC global tax return on Jersey Tax website

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