Pillar Two Product Delivery Services

IMPORTANT NOTICE –This opportunity is currently restricted to Jersey based / domiciled companies. There is a requirement that bidders / suppliers provide the service and the resources locally so an on-island presence Mon to Fri, working in situ with Digital Services and Revenue Jersey teams in GOJ HQ Union Street, Jersey is requested. The successful supplier must have a Jersey address.

GoJ are seeking local providers due to the urgent nature of the request and the need to embed resources within the team.

Project Scope
Government of Jersey (GoJ) are seeking providers with the capability to provide experienced, expert resources to augment our own resources and establish a multi-disciplinary, GoJ product team. The objective of this product team is to build a new digital service in support of Jersey’s new “Pillar Two” tax regime for large multinational enterprises (see context below).
Pillar Two Context

Legislation unanimously approved by the States Assembly in October 2024 created a new standalone tax regime “Pillar Two” for large multinational enterprises (MNEs). Jersey has made a commitment to implement Pillar Two by enacting an Income Inclusion Rule (IIR) and a domestic multinational corporate income tax (MCIT) from 2025.

The Pillar Two regime is based on financial accounting figures with enumerated adjustments, it will operate on a brand-new base, completely different from the way the current zero/ten tax system is computed. In-scope groups will be filing Global Anti-Base Erosion Model Rules (GloBE) Information Returns (GIR) globally which contain data to be used in computing the new Jersey MCIT.

Revenue Jersey will require additional international tax and accounting staff over a phased period of 3-4 years, in order to provide first-class customer service to the large MNE groups that will be paying tax under Pillar Two in Jersey.

In the first instance, new capabilities to register taxpayers and agents will be available in August 2025. This will allow customers to engage & use the new system by the 31 December 2025 registration deadline.

Pillar Two: Global Minimum Tax
The OECD’s Pillar Two is part of a global initiative to ensure that MNEs pay a minimum level of tax on their profits, regardless of where they operate. This initiative is a key component of the OECD/G20 Base Erosion and Profit Shifting (BEPS) project, which aims to address tax challenges arising from the digitalisation of the economy.

Jersey’s Implementation of Pillar Two
Jersey has implemented Pillar Two by adopting the Multinational Corporate Income Tax Law and the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) Law. The obligations on certain taxpayers under these laws can broadly be housed into three key components:
• Multinational corporate income tax (MCIT)
• Income inclusion rule tax (IIR)
• GloBE information return (GIR)

The Pillar Two rules only apply to MNEs with a global annual turnover of more than €750 million in at least two of the prior four years. All other MNEs below this threshold will remain under Jersey’s existing corporate income tax regime (zero/ten). For MNEs in scope of Pillar Two, the new rules apply for the accounting periods beginning on or after 1 January 2025.