Jersey proposes statutory MCIT exclusion for property unit trusts

Article 7 of the current Multinational Corporate Income Tax (Jersey) Law 2025 excludes investment entities, insurance investment entities and securitisation entities from the definition of a Jersey constituent entity. It does not contain a separate property-unit-trust category.^[2]

Article 56 of the draft would add that category. For a fiscal year, a unit trust would qualify where, at the year end, at least 75% of the value of its trust property is directly or indirectly attributable to immovable property held for letting or hiring out, including short-term use, or used for purposes ancillary to that rental business.^[1]

The draft adopts the meanings of “unit trust” and “trust property” in Article 1 of the Trusts (Jersey) Law 1984. Those definitions concern investment participation through a trust and property held in it; a property label alone does not establish qualification.^[1][3]

The explanatory note states that the exclusion would remove the qualifying entity’s income from the group’s MCIT calculation regardless of whether another Article 7 exclusion applies. Article 72 proposes commencement on 1 January 2027; enactment must still be checked.^[1]

Groups should identify the trust’s legal form, fiscal year end, property valuation and direct or indirect rental use before assessing the proposed exclusion. This focused measure is not a conclusion on the bill’s separate incentive or IIR proposals.^[1][3]