Who it applies to
Pillar Two applies only to large multinational enterprise (MNE) groups.
In Jersey, Pillar Two is implemented through the Multinational Corporate Income Tax (MCIT) and Income Inclusion Rule (IIR). MCIT may apply if your MNE group includes one or more Jersey constituent entities.
MCIT and IIR do not apply to individuals or most local businesses.
Consolidated revenue threshold
MCIT applies to MNE groups with consolidated annual revenue that averages at least €750 million.
This threshold is assessed at group level, based on the consolidated financial statements of the group’s Ultimate Parent Entity (UPE) for each accounting period.
If your group’s consolidated revenue is below €750 million, Pillar Two and MCIT do not apply.
Jersey constituent entities
An entity is a Jersey constituent entity where:
- it meets the definitions in the OECD Model Rules, and
- it is not: an investment entity, an insurance investment entity, or a securitisation entity
Detailed commentary on location of entities and the entities listed above is set out in the MCIT technical guidance.
What to do if you are in scope
If MCIT applies to your MNE group in Jersey, you must self-assess your MCIT position.
Your obligations fall into two stages:
One off set up requirements
If you are in scope, you must:
- register for MCIT
- confirm your group and Jersey constituent entities' details
You must register even if no MCIT is payable, for example where a de minimis exemption applies.
Ongoing compliance obligations
Once registered, you will have ongoing obligations.
You will need to:
- calculate whether any MCIT is due for each accounting period
- pay MCIT where it is due
- meet ongoing reporting requirements, including submitting MCIT returns
- consider whether any Pillar Two filings are required at group level (for example under the IIR or GloBE Information Return (GIR))
A summary of these obligations, including key actions and timing, is set out below.
The deadlines are the same for all in scope MNE groups and are based on the accounting period of the group’s ultimate parent entity (UPE).
Register your Jersey constituent entities for MCIT purposes
| One-off
| Before the end of the first accounting period for which MCIT applies to the in-scope MNE group
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Pay 50% of reasonable estimate of MCIT amount
| Ongoing, annually
| 5 months after the end of the MNE group’s accounting period
|
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Submit the MCIT return
| Ongoing, annually
| 12 months after the end of the MNE group’s accounting period
|
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Pay the remaining balance of the MCIT amount
| Ongoing, annually
| 12 months after the end of the MNE group’s accounting period
|
|---|
What happens next
If MCIT applies to you, register for MCIT and manage your MCIT obligations through the Pillar Two Platform.
The platform is secure and allows you to manage your self assessed MCIT obligations, including the ability to:
- manage group and entity details
- generate payment references
- manage future MCIT reporting
At this moment in time, the platform supports your ongoing compliance obligations, helping you keep track of required filings, payments and future deadlines. The platform will develop over time to include additional functionality, such as submitting your MCIT returns.