Register for Multinational Corporate Income Tax (MCIT)

A Jersey incorporated but non-Jersey tax resident company (under Article 123 of the Jersey Income Tax Law) is treated as located outside of Jersey for Pillar Two purposes, and therefore it will not be regarded a Jersey Constituent Entity. As such, MCIT does not apply to these companies and these are not required to be included in an MCIT registration.

However, if a non-Jersey tax resident company carries on business through a permanent establishment (as defined in Article 9 of the Multinational Corporate Income Tax (Jersey) Law 2025 (MCIT Law)) in Jersey, the Jersey permanent establishment is treated as a separate Jersey Constituent Entity, subject to MCIT and required to register for MCIT.

For more information on the MCIT ​treatment and location of Jersey entities, go to our Technical Guidance.

Multinational Corporate Income Tax (MCIT) guidance (Pillar Two)

​​Avoiding MCIT registration delays (Section 1 and Section 4 of the form)

To ensure timely processing of an MCIT registration, all Tax Identification Numbers (TINs) provided must be correct and valid. Only Jersey registered TINs should be used.

Where any TIN details are incorrect, Revenue Jersey will contact the applicant to request clarification.

If a TIN is valid but the name been entered incorrectly, Revenue Jersey may amend the entity name information in order to expedite authorisation of the registration if there was a just a typo in the Entity's name.

​The entity required to act as the Reporting Entity (Section 1 of the form)

In accordance with Article 8 of the Multinational Corporate Income Tax (Jersey) Law 2025, the Reporting Entity in relation to an in-scope MNE group is determined as follows:

• where there is a Jersey Constituent Entity that is the Ultimate Parent Entity (UPE) of the group, that entity must be required to act as the Reporting Entity
• where there is no Jersey located UPE, but there is a Jersey located Intermediate Parent Entity (IPE), the Jersey located IPE must act as the Reporting Entity
• where there is neither a Jersey located UPE nor a Jersey located IPE, a Jersey Constituent Entity of the group must be appointed as the Reporting Entity
  

​Duplicate registrations

A separate registration is not required for the Reporting Entity alone. A single MCIT registration should include the Reporting Entity and all applicable Constituent Entities. Any duplicate registrations submitted will be rejected.

Whilst a Reporting Entity is a Jersey Constituent Entity, it should not also be listed in the Jersey Constituent Entities section of the application. The Reporting Entity is declared separately within the Reporting Entity section of the application and does not need to be duplicated.

​Missing or Invalid Tax Agent Letters of Authority (Section 5 of the form)

Where a tax agent has been appointed to act in relation to MCIT matters, a valid letter of authorisation must be submitted in Section 5 of the MCIT registration.  Registrations will not be approved until a valid letter of authorisation has been received.

Revenue Jersey will contact the applicant (not the tax agent) to obtain the required documentation before the registration can be approved.

​Errors with applying the Income Inclusion Rule (IIR) (Section 1 of the form)

Where the reporting entity is an Intermediate Parent Entity (IPE), the entity is required to inform us on whether or not the IIR would apply in Jersey under the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 2025 (IIR Law), which implements the Income Inclusion Rule (IIR) published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS".

The IIR will apply in Jersey if an entity is a 'qualifying entity' as defined in Article 10 of the IIR Law. A 'qualifying entity' is an entity that:

1. ​is located in Jersey
2. is not an Excluded Entity
   
3. owns an ownership interest in a constituent entity that is not located in Jersey and
   
4. either (a) is the ultima​te parent entity (UPE) of the MNE Group or (b) is an IPE of an MNE group, and neither the UPE nor another IPE that holds an ownership interest in the entity mentioned at number 3, is required to apply a qualified IIR

This requires looking at the Group's global organisational chart and understanding how Pillar Two has been implemented in the relevant holding jurisdictions for the Fiscal Year. Where needed, the appropriate tax advice should be sought.

Accordingly, where either the UPE or another IPE in a MNE Group are residents in jurisdictions that have implemented a Qualified IIR,​ no separate IIR return is required to be submitted in Jersey in respect of the relevant filing period. As such, the Reporting Entity that is an IPE is not required to apply the IIR and shall disclose 'No' to the Question 'Is the IPE required to apply to the income inclusion rule?' in Section 1 of the MCIT registration.

​Economic Substance regulations and Entities registered for MCIT

Entities subject to the economic substance rules (Jersey tax residents which have income from a relevant sector) will continue to be in scope of the rules and will be required to meet the economic substance requirements. The MCIT return will include a section on economic substance to be completed by the reporting entity in respect of all the Jersey constituent entity in an in-scope MNE group. 

​Registering for MCIT and the de minimis rules

An in-scope MNE Group that satisfies any of the de minimis exemptions in Article 5 of the MCIT Law, it is still required to register for MCIT, even if it elects to apply an exemption. 

The de minimis election is an annual election and it must be made by giving written notice to the Comptroller in the MCIT return. Where the election is made, each of the respective Jersey constituent entities will be required to file a corporate tax return.