At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Revenue Jersey (Comptroller of Revenue). Summaries are simplified; check the linked official source before relying on them.
The law
#Jersey has no transfer pricing statute and no arm's length rule in the Income Tax (Jersey) Law 1961. No 2024 transfer pricing law for large businesses was found on gov.je or jerseylaw.je. The closest tool is Article 134A of the 1961 Law, a general anti-avoidance power: the Comptroller may raise an assessment where the main purpose, or one of the main purposes, of a transaction is to avoid or reduce income tax, unless it was a bona fide commercial transaction. Most companies pay tax under the 0/10 regime and file a company tax return under the 1961 Law. From 2025, Jersey entities of large multinational groups (consolidated revenue of EUR 750m or more) pay a 15% Multinational Corporate Income Tax (MCIT) instead of income tax, and a Jersey parent may owe income inclusion rule (IIR) tax.
Documentation
#There is no master file, local file or other transfer pricing documentation rule. A taxpayer should be able to show on request that its related party dealings are at arm's length, but this comes from practice and general tax law, not from a stated duty (per Big 4 and Grant Thornton guides, not an official page). No thresholds apply. Normal record keeping rules apply to the tax return.
Methods
#No methods are set out in Jersey law or in Revenue Jersey guidance read for this research. In practice Jersey is said to look at OECD guidance as an aid, and interest relief can be limited where interest is above what a commercial lender would charge (PwC Tax Summaries, secondary source). There are no thin capitalisation rules.
Penalties
#There are no transfer pricing penalties. Late corporate tax return: GBP 300, then GBP 100 for each month after the first three months outstanding, up to nine months. CbC (2016 Regulations): GBP 300 for failing to file or notify, up to GBP 60 a day after that, up to GBP 1,000 a day after 30 more days, and up to GBP 3,000 for knowingly inaccurate information. MCIT: late return GBP 300 plus GBP 100 for each complete month, up to GBP 1,200 in total (Art. 33), GBP 3,000 for registration failures (Art. 32), simple interest on late tax (Art. 30, none under GBP 300). IIR: up to GBP 3,000 for failing to notify, and GBP 1,000 plus GBP 1,000 per complete month for a late return, up to GBP 12,000 (Arts. 27 and 28).
Pillar Two
#Jersey has two laws in force from 1 January 2025, both given effect as if enacted on 22 October 2024: the Multinational Corporate Income Tax (Jersey) Law 2025 (L.7/2025) and the Multinational Taxation (Global Anti-Base Erosion, IIR Tax) (Jersey) Law 2025 (L.8/2025). Both apply to fiscal years beginning on or after 1 January 2025. MCIT is a 15% tax on the Jersey profits of in-scope groups, built on the GloBE rules; the law does not call it a qualified domestic minimum top-up tax. The IIR Law switches off the UTPR. MCIT: register before the end of the first fiscal year, pay 50% of an estimate 5 months after year end, and file the return and pay the rest 12 months after year end. IIR: the Jersey reporting entity notifies the Comptroller, and a Jersey qualifying (parent) entity files the GloBE Information Return and IIR return and pays any IIR tax, 15 months after year end, or 18 months for the first fiscal year the Law applies to the group.
Other rules
#Country-by-Country reporting is under the Taxation (Implementation) (International Tax Compliance) (Country-by-Country Reporting: BEPS) (Jersey) Regulations 2016 (EUR 750m threshold, report due 12 months after the end of the reporting period, notification by the last day of the reporting period). Economic substance for companies is in the Taxation (Companies - Economic Substance) (Jersey) Law 2019, with the declarations made in the corporate tax return. Unilateral rulings and APAs are possible only in exceptional cases per secondary sources. Company tax returns are filed online and no extension process was found. Jersey is not in the EU, so no EU DAC6 or directive applies.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC notification to the Comptroller Due on or before the last day of the reporting period itself, the accounting period the CbC report covers (Reg 5(9); the report is "in respect of AP+1" and notice is due by the last day of AP+1). The Jersey entity names the entity that will file and where. Late notice: GBP 300 (Reg 7). | Last day of the fiscal year (e.g. Dec 31, 2025) | Jersey entities of an in-scope MNE group that file, or that rely on another group entity to file (Reg 5). | Jersey CbC Regulations 2016 (RO 128/2016) |
| 2 | Register for MCIT (one-time) Register before the end of the first fiscal year to which the MCIT Law applies to the group (Art. 23(4)(a)). For groups in scope from the start that is the first fiscal year beginning on or after 1 January 2025, so the row shows only for year ends up to 30 December 2026. A group that comes into scope later registers before the end of its own first in-scope year; a newly qualifying entity within 6 months of joining. Changes within 6 months. Penalty GBP 3,000 (Art. 32). | Last day of the fiscal year (e.g. Dec 31, 2025) | In-scope MNE groups with a Jersey constituent entity. The reporting entity (the Jersey UPE, else the only Jersey intermediate parent, else a nominated Jersey entity) or a specially appointed tax agent registers each Jersey constituent entity online. | MCIT (Jersey) Law 2025 Art. 23 |
| 3 | MCIT first instalment (50% of estimate) 50% of a reasonable estimate of MCIT, due 5 months after the end of the fiscal year (Arts. 18(2)(a) and 19). The law has no first-year exception. Revenue Jersey says that if the date is a weekend or bank or public holiday the payment must arrive by the end of the previous working day. Pay in GBP. | 5 months after year end (e.g. May 29, 2026) (moved from May 31, 2026, a Sunday) | In-scope MNE groups with Jersey constituent entities. | gov.je: How to pay MCIT |
| 4 | Company income tax return (Article 16 return with Article 20B financial statements) Due by midnight on 30 November in the year following the year of assessment (Income Tax (Jersey) Law 1961 Art. 17A(2)(a)(i)). The year of assessment is the calendar year, and a company is taxed on its financial period ending in that year, so a year end in Y gives 30 November of Y+1. The law sets no weekend move, so the date is kept. Late penalty GBP 300, then GBP 100 a month after three months, up to nine months. No extension process found. Jersey entities of a group that pays MCIT are outside income tax and do not file this return for that year (Arts. 120AB and 120AC). | Fixed calendar date (e.g. Nov 30, 2026) | All Jersey resident companies and non-resident companies with a Jersey permanent establishment, including those taxed at 0%. | gov.je: Company tax return guidance notes |
| 5 | Country-by-Country report Filing deadline is 12 months after the end of the accounting period the report covers (Reg 1). Penalties: GBP 300, then up to GBP 60 a day after notice of the penalty, and up to GBP 1,000 a day if the Commission so decides after 30 more days (Regs 7, 8, 14). | 12 months after year end (e.g. Dec 31, 2026) | Jersey resident ultimate parent of an MNE group with consolidated revenue of EUR 750m or more, or a Jersey entity that must file when the parent does not file or exchange (Regs 4 to 6). | Jersey CbC Regulations 2016 (RO 128/2016) |
| 6 | MCIT return Due 12 months after the end of the fiscal year (Art. 24). Late penalty GBP 300 within a month, then GBP 100 for each complete month, up to GBP 1,200 in total (Art. 33). The de minimis exemption election is due by the return due date (Art. 6). No weekend rule found for the return. | 12 months after year end (e.g. Dec 31, 2026) | In-scope MNE groups with Jersey constituent entities. Filed by the reporting entity online. | gov.je: How to complete the MCIT return |
| 7 | MCIT balance payment The rest of the MCIT is due by the return due date, 12 months after fiscal year end (Art. 18(2)(b)). Revenue Jersey says a payment due on a weekend or bank or public holiday must arrive by the previous working day. Simple interest on late tax (Art. 30), none under GBP 300. | 12 months after year end (e.g. Dec 31, 2026) | In-scope MNE groups with Jersey constituent entities. | gov.je: How to pay MCIT |
| 8 | IIR notification of the entity filing the GloBE return Written notice (Art. 14) stating whether the reporting entity files the GloBE Information Return or, if not, which group entity files it and where. Due 15 months after the fiscal year end, or 18 months for the first fiscal year the IIR Law applies to the group (Art. 14(4)). For groups in scope from the start that first year is the first fiscal year beginning on or after 1 January 2025, which is why the 18 month period runs to year ends of 30 December 2026. Groups that come into scope later also get 18 months for their first year. Max penalty GBP 3,000 (Art. 27). | 18 months after year end (first year) (e.g. Jun 30, 2027) | The reporting entity of an in-scope MNE group: the Jersey qualifying (IIR-paying parent) entity, or, if none, a Jersey entity the Comptroller designates (Arts. 8 and 13). | IIR Tax (Jersey) Law 2025 Art. 14 |
| 9 | GloBE Information Return, IIR return and IIR tax payment The GloBE Information Return (Art. 15), the IIR return with the entity's own assessment (Arts. 18 and 19) and any IIR tax (Art. 12(2)) are due by the same date: 15 months after fiscal year end, 18 months for the first fiscal year the Law applies to the group (Art. 20). Late return penalty GBP 1,000 plus GBP 1,000 per complete month, up to GBP 12,000 (Art. 28). Simple interest on late tax, none under GBP 300 (Art. 25). | 18 months after year end (first year) (e.g. Jun 30, 2027) | Only a Jersey qualifying entity: a Jersey ultimate parent, or a Jersey intermediate or partially-owned parent that must apply the IIR (Art. 10). Jersey subsidiaries of foreign parents do not file a GloBE return in Jersey (Art. 7(2)). | IIR Tax (Jersey) Law 2025 Arts. 12, 15, 18 to 20 |
Official texts
#- Multinational Corporate Income Tax (Jersey) Law 2025 (L.7/2025) (Open States Assembly Licence (OSAL-J) v.1)
- Multinational Taxation (Global Anti-Base Erosion, IIR Tax) (Jersey) Law 2025 (L.8/2025) (Open States Assembly Licence (OSAL-J) v.1)
- Income Tax (Jersey) Law 1961 (incl. Art. 134A and Art. 17A) (Open States Assembly Licence (OSAL-J) v.1)
- Taxation (Implementation) (International Tax Compliance) (Country-by-Country Reporting: BEPS) (Jersey) Regulations 2016 (Open States Assembly Licence (OSAL-J) v.1)