Double Taxation Agreements: Jersey: Income from a UK source paid to a resident of Jersey - Industrial or commercial profits paragraph
Paragraph 3 provides for the relief from UK tax of ‘the industrial or commercial profits of a Jersey enterprise’.
In practical terms, this means that we can allow relief on UK interest paid to a bona fide bank in Jersey, since it can be held that interest represents part of the bank’s profits as defined by paragraph 3.
So if you get a claim from a bank in Jersey you will need to;
- be certain that it is a recognised bank - the Banker’s Almanac will help you, or HMRC users may refer to theBanks List
- consider if you should have the loan agreement reviewed by the HMRC office which deals with the accounts of the UK borrower - see INTM342010
If these checks are satisfactory, you can allow full relief.
But if you receive a claim from a Jersey enterprise in respect of any other category of income, please refer to CAR Technical Advice Group before taking any action.