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Information and public services for the Island of Jersey

L'înformâtion et les sèrvices publyis pouor I'Île dé Jèrri

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General tax rulings

General tax rulings apply to groups or types of taxpayers or may be given in relation to a defined set of circumstances or activities, rather than applying to a specific taxpayer(s).

They typically provide guidance on the position of Revenue Jersey on such matters as interpretation of law and administrative practice and on their application to taxpayers generally, to a specified group of taxpayers or to specified activities.

We will publish all general tax rulings on after being granted. They can be applied by taxpayers to their relevant activities or transactions without contacting Revenue Jersey or making an application for a specific ruling.

Interpretation of the Income Tax Law in regard to Interest in Possession Trusts (GTR 1)

Publication date Tuesday 23 April 2019

Where the beneficiary of an Interest in Possession Trust is both entitled to the income of the trust and is in receipt of the income directly:

  1. the trustee(s) of the trust will not be liable / assessable to Jersey income tax in respect of the income arising in respect of that interest in possession; and
  2. the beneficiary will be assessable to Jersey income tax in respect of their interest in possession

Interpretation of the word 'arising' in the context of the Jersey Income Tax Law (GTR 2) 

Publication date Tuesday 23 April 2019

The word 'arising' is not defined in the Jersey Income Tax Law. For the purpose of the Law interest 'arises' when it is received or made available to the recipient. Interest has been made available if it is credited to an account on which the account holder is free to draw.

Tax treatment of Luxembourg special limited partnerships (“SCSp”) for Jersey tax purposes (GTR 3)

Publication date Thursday 30 July 2020 

The Comptroller of Revenue is of the view that a Luxembourg special limited partnership falls within the definition of “limited partnership” as prescribed at Article 76A(6) of the Income Tax Jersey (Law), 1961. As such the provisions included within the entirety of Article 76A will apply to the SCSp for Jersey tax purposes.

Tax treatment of a shareholder's allocated share of specified profits where two companies merge in accordance with Jersey company law (GTR 4)

Publication date 12 January 2021

This general ruling applies where there is a bona fide merger between two or more companies in accordance with Jersey company law and where at all times investors own shares in the same ratio in each of the companies which are party to the merger. In these circumstances, the distributable profits of the merged companies will be regarded as consolidated in the surviving company. 

For the purpose of determining the value of an individual's share of specified profits at the point when a distribution is made by the surviving company, this should be computed  as the sum of the individual's specified profits of each of the merging companies at the time the companies merged together with any post-merger specified profits accruing to the individual.

Jersey Purpose Trusts within scope of Concession M1 where no Jersey resident has an interest in the trust (GTR 5)

Publication date 24 March 2021

The concept of the non-charitable Purpose Trust has been provided for in Jersey Law since 1996 via the Trusts (Amendment No 3) (Jersey) Law 1996 which amended the Trusts (Jersey) Law 1984.

The Jersey tax treatment of trustees provided for in published Concession M1 - insofar as they apply to a trust with non-resident beneficiaries - will apply equally to the trustees of a Purpose Trust with no beneficiaries where no Jersey resident (other than a local charity) has an interest, or is intended to have an interest, whether during or at the end of the trust period, in that Purpose Trust.

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