Taxation of undistributed profits (FOI)

Request

Please advise the total amount estimated for companies as being undistributed profits taxed at 0% and due to Jersey resident beneficial owners as at 31 December 2015, 2016, 2017 and 2018. Please show each year separately. If the comptroller of taxes (or any other States department) does not have this information, please let me know.

Response

The Comptroller of Taxes does not hold this information and it cannot be estimated from available data.

In order to estimate the undistributed profits taxed at 0% and due to Jersey resident beneficial owners, Revenue Jersey would require at least the following data.

• the amount, or a reasonable estimate of the amount, of profits accruing within 0% companies ultimately owned by Jersey residents, since the introduction of the zero / ten regime of company taxation on 1 January 2009

• in respect of company distributions made in any one year; the period of accounts to which the distribution related (because a distribution made by a company in a financial period may be made out of the profits of a previous financial period)

• the percentage of ultimate ownership of those companies by Jersey residents – to include details of changes in the ultimate Jersey resident ownership in each period

The Comptroller has not collected or held the above information on a systematic basis since the commencement of the zero / ten regime. No other Government department will hold any of this data.