JATCO and the JCOA want to reduce the number of non-compliant UK-registered entities   

JATCO and the JCOA have asked its members to check whether they are connected to non-compliant UK-registered entities (see email in source notes)

UK COMPANY LAW

• UK company law requires every company to disclose the individuals who control it—their “person with significant control” (PSC). However, the rules are widely ignored.

JERSEY AUDIT

• The following will help you check whether you are connected to non-compliant UK-registered entities.

TAX POLICY ASSOCIATES AND DAN NEIDLE 

1. Tax Policy Associates and Dan Neidle:-
   1. Found that around 50,0001 UK companies hide their true ownership by unlawfully listing a foreign company as their PSC—that’s not permitted.  
   2. These 50,0000 are shown on an interactive map of UK companies registered at the UK Companies House and their PSCs.
   3. Have created two interactive maps
      1.  UK companies with hidden ownership - https://taxpolicy.org.uk/wp-content/assets/pscs_map_v3.html
      2. Interactive map of all foreign entities holding English/Welsh real estate (v2) https://taxpolicy.org.uk/2024/01/25/overseas/

4. According to the interactive maps, many companies do not declare individuals but report a company as an owner.

INTERACTIVE MAP OF ALL UK COMPANIES WITH HIDDEN OWNERSHIP -   

• THE INTERACTIVE MAP OF ALL UK COMPANIES WITH HIDDEN OWNERSHIP IS HERE
• https://taxpolicy.org.uk/wp-content/assets/pscs_map_v3.html
• You can zoom into the map and identify Jersey, then zoom in further and identify your firm on the map. The map will also show which UK companies are affected by your firm
• JERSEY AND GUERNSEY AND HIGHLIGHTED BELOW

SECOND INTERACTIVE MAP OF ALL FOREIGN ENTITIES HOLDING ENGLISH/WELSH REAL ESTATE  

• In this second map, you will also see the name of the foreign entity –
• https://search-property-information.service.gov.uk/search/search-by-title-number 

• If you click on a property, you can see its land registry details. Clicking on that takes you to Companies House and (if there’s one precise match for the company name) straight to the registered beneficial owners of the company.
• https://search-property-information.service.gov.uk/search/search-by-title-number

SOURCE

• https://taxpolicy.org.uk/wp-content/assets/pscs_map_v3.html
• https://taxpolicy.org.uk/2024/01/25/overseas/ -
• The UK PSC Register Requirements - Stevens & Bolton LLP https://www.stevens-bolton.com/site/insights/briefing-notes/uk-psc-register
• a guide for UK companies on their obligations - Travers Smith https://www.traverssmith.com/knowledge/knowledge-container/the-psc-regime-a-guide-for-uk-companies-on-their-obligations/

Dear members

Some of you may follow Dan Neidle, the entertaining and interesting tax adviser, on Linkedin (and other social media).  He often posts about relevant and topical matters, however, one of his recent posts included an interactive map, created by him/his firm, relating to UK Companies House and persons of significant control (PSC).

UK law requires a PSC to be named, and that party must be a person – one or more individuals.  According to the interactive map, there are many companies around the world who are not declaring individuals but are instead reporting a company as an owner.  It is possible to zoom into the map and identify Jersey and you can then zoom in further and identify your firm on the map.  The map will also show exactly which UK companies are affected at your firm.

Here is a link Map of overseas holders of UK real estate - Tax Policy Associates

(If you are hesitant about clicking on a link please look up Tax Policy Associates – which takes you to taxpolicy.org.uk – if you look up ‘map’ on the website the results will take you to the interactive map)

We appreciate that where, for example, limited services are provided to the UK company, that filings may be done perhaps by a firm in the UK.  However, it would be prudent to look at this and see if any of the PSC’s can be remedied to show a natural person.  It may be the case that you have contact with the party doing the filings, in which case, perhaps you could share the advice above.  It would be of benefit to Jersey to reduce the number of non-compliant entities, if possible.  Please note that JATCO and the JCOA are sharing this same email therefore we extend our apologies if you perhaps receive this twice.

We hope this is of assistance and thank you for taking the time to look at this.

Many thanks

Chair - JCOA