Jersey has implemented the OECD’s Country-by-Country Reporting (CbCR) framework under BEPS Action 13, reinforcing its commitment to global tax transparency. The reporting obligations apply to multinational enterprise (MNE) groups meeting specific revenue thresholds and involve both notification and filing requirements.

This guide provides an overview of Jersey’s CbCR regime, including who must report, how to comply, deadlines, and consequences of non-compliance.

Regulatory Framework

• Authority: Jersey Taxes Office (Revenue Jersey)
• Legislation:
  • Income Tax (CbCR) (Jersey) Regulations 2016
  • Amendments aligned with OECD and EU standards
• International Engagement:
  • Jersey is a signatory to the OECD Multilateral Competent Authority Agreement (MCAA)
  • Member of the Inclusive Framework on BEPS

CbCR Filing Requirements

• Who Must File:
  • Ultimate parent entities (UPEs) tax resident in Jersey of MNE groups with annual consolidated revenue of EUR 750 million or more in the previous fiscal year
  • Jersey constituent entities of foreign MNEs may be subject to surrogate or secondary filing requirements if the UPE’s jurisdiction does not exchange CbC reports
• CbCR Notification:
  • All Jersey entities of an MNE group must notify Revenue Jersey about the identity and tax residency of the reporting entity
  • Notification deadline: by the end of the reporting fiscal year
• CbCR Submission:
  • Deadline: within 12 months of the end of the reporting fiscal year
  • Submission is made electronically in OECD-compliant XML format via the Jersey Taxes Office portal

Penalties for Non-Compliance

• Fines up to GBP 3,000 for failure to file or provide inaccurate information
• Additional penalties for continued non-compliance

Important Considerations

• CbCR data is automatically exchanged with participating jurisdictions
• Jersey follows OECD standards, including the Master File, Local File, and CbC Report structure
• Entities must ensure consistency in transfer pricing documentation across jurisdictions

Useful Resources

• Revenue Jersey (CbCR guidance): https://www.gov.je/TaxesMoney/InternationalTaxAgreements/Pages/CountryByCountryReporting.aspx
• OECD CbCR Portal: https://www.oecd.org/tax/beps/country-by-country-reporting.htm