On 19 May 2023, the 3 Crown Dependencies made a statement on an intended approach to implementation of the Organisation for Economic Co-operation and Development (OECD) Pillar Two global minimum tax framework for large multinational groups.
Joint statement on Pillar Two by the Crown Dependencies
The treasury ministers of Jersey, Guernsey and the Isle of Man have jointly announced their intentions in relation to Pillar Two implementation. Each Island intends to implement an Income Inclusion Rule (IIR) and domestic minimum tax from 2025, while continuing to monitor global implementation.
This statement gives in-scope businesses certainty in relation to the 2024 tax year.
Crown Dependencies joint statement
Local press release on the Crown Dependencies announcing agreed approach to Pillar Two Framework
Key principles to Jersey's approach
The key principles on which we have consulted industry and which guide Jersey's approach to Pillar Two are:
- our commitment to maintaining an attractive business environment, based on certainty and simplicity is unchanged
- most companies in Jersey will be outside the scope of the OECD two-pillar initiative and should therefore see no change in their corporate tax rate
- Jersey will implement the minimum standards in the OECD two-pillar solution
- Jersey would be well placed to implement GloBE if it chooses to do so, since the Island has a trusted and well-resourced tax authority administering an existing corporate tax regime
- the decision on GloBE will not be based on short-term revenue-raising considerations
These principles are set out in our tax policy reflections paper and are still relevant.
Jersey's tax policy reflections paper on the OECD Pillars
Background on the OECD Pillars
Since 2019, the OECD Inclusive Framework has been working to address the tax challenges arising from the digitalisation of the global economy. This work resulted in a two-pillar initiative announced in October 2021, to which a political commitment was made by 137 jurisdictions, including Jersey.
Pillar One concerns only the very largest multinational groups of companies which have an annual turnover exceeding €20 billion. This pillar creates new rules about where tax is to be paid based on where the group's customers are based. The OECD's October 2021 Statement says that Pillar One is intended to be a minimum standard that jurisdictions will be required to implement within their domestic laws. Pillar One is still being developed.
The Pillar Two GloBE framework is a new set of international tax rules that will require in-scope multinational groups to pay a 15% minimum effective rate of tax in every jurisdiction in which they operate. The rules apply to groups with more than €750 million global annual revenue with an exclusion for certain investment entities, including investment funds. The starting point for the determination of GloBE income or loss will be the group's consolidated financial accounting position, to which adjustments will be made to calculate the final defined GloBE income. All other businesses that are below the threshold, including small and medium-sized companies and partnerships, will see no impact as they remain under Jersey's existing corporate income tax regime.
Tax Challenges Arising from the Digitalisation of the Economy - Global Anti-Base Erosion Model Rules (Pillar Two) on OECD
The Subject to Tax Rule (STTR) is included in Pillar Two. It is intended to ensure that double tax agreements do not prevent certain payments made from developing countries from being taxed at a rate of at least 9%. The precise scope of the STTR is still under development.
Queries and feedback
Interested stakeholders can email queries regarding the announcement or related issues to Revenue Jersey officers at
tax.policy@gov.je with a subject line of 'Pillar Two Implementation'.
Revenue Jersey values open dialogue with taxpayers and their advisers, and invites feedback on the outlined issues or confidential discussions of specific cases.
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