Revenue Jersey occasionally release practice notes on technical tax matters. These are primarily aimed at tax and legal professionals.
Assignment of income
Some tax planning schemes allow an individual to assign their right to income to a connected party while retaining the beneficial interest in the asset. The individual then claims they should not be taxed on this income. Revenue Jersey do not accept that these schemes are effective for Jersey income tax purposes.
Practice Note - Assignment of income
Share schemes
A taxable emolument can arise from schemes which award shares or options to buy shares at less than their market value. However, the terms of these schemes are often varied and complex. Unless otherwise determined, Jersey follows the principles set out in UK case law for the taxation of officer and employee share scheme awards.
Practice Note - Taxation of award schemes
Self-storage businesses
Revenue Jersey considers self-storage businesses should be taxed on a Schedule A basis. If any self-storage business believes it is a trading concern taxable on a Schedule D Case I basis, they should write to Revenue Jersey setting out why they consider Schedule A is not appropriate. Otherwise, all self-storage businesses will be assessed to Schedule A from 1 January 2024.
Practice Note - Self-storage businesses
Carried interest
Jersey's long-standing position on carried interest is that it is a share of capital profits and not taxable. This accords with the UK's approach and relevant case law.
Statement of practice - carried interest
Investments portfolio accounting
The requirement for accounting records to
identify all transactions further to Taxation (Accounting Records) (Jersey)
Regulations 2013 is relaxed where, in limited circumstances, certain
investments are accounted for on a portfolio basis. This practice note
does not apply to income generated by such investments.
Practice Note - Investments portfolio accounting