Significant property transactions that have recently come to Jersey include the formation of a unit trust in connection with the 215m financing of Fosse Park, one of the leading retail parks in the UK, and a unit trust established in Jersey to provide development funding for Chiswick Park in London. The acquisition of the Shell-Mex building in London and other major property transactions have been financed by Jersey structures, including limited partnerships. Jersey structures have been used in relation to insurance-related transactions and are increasingly popular for the raising of Tier 1 capital by banks, as seen in the issue of preference shares by Fortis Capital Company for Fortis Bank Nederland. A Jersey limited partnership was also used recently to raise tax efficient finance which incorporated features both of debt and of equity. Transactions such as these, together with bank deposits exceeding 100bn placed with Jersey banks and the presence in Jersey of leading financial services providers and their professional advisers, make Jersey an attractive place to do business.
Tax is often the first that is considered.
In that regard a range of possible tax treatments for vehicles is available in Jersey. A Jersey company in which local residents have no ownership interests may be treated as non-resident for tax purposes in Jersey in which event it will pay no tax on income from a source outside Jersey. In certain circumstances it is, however, desirable for a company within a structure to pay tax at a particular level. Jersey offers that flexibility. For these purposes an international business company or an income-tax company may provide the best solution depending upon the appropriate level of tax.