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 taxpayers.
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 gov.je 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 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:
- the trustees of the trust will not be liable to Jersey income tax in respect of the income arising in respect of that interest in possession
- 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 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 certain foreign vehicles - Luxembourg 'SCSp', Luxembourg 'SCS', French 'SLP' Jersey tax purposes (GTR 3 - as amended)
Publication date 15 March 2023 (originally published 30 July 2020)
The Comptroller of Revenue is of the view that certain overseas vehicles fall within the definition of 'limited partnership' as prescribed at Article 76A(6) of the Income Tax Law. As such, the provisions included within the entirety of Article 76A will apply to these vehicles, and their members as partners, for Jersey tax purposes.
The Comptroller also confirms that these vehicles will be treated as 'foreign limited partnerships' for the purposes of the Taxation (Economic Substance - Partnership) (Jersey) Law 2021.
These vehicles are:
- sociéte de libre partenariat (SLP) under French Law
- société en commandite simple (SCS) under Luxembourg Law
- société en commandite spéciale (SCSp) under Luxembourg Law
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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