Barbados: Rules requiring country-by-country reporting enacted

Legislation requiring country-by-country reporting has been enacted

Legislation requiring country-by-country reporting has been enacted

Legislation requiring country-by-country (CbC) reporting has been enacted, with an effective date of 31 December 2021.

CbC reporting will provide the tax authorities with additional information on cross-border corporate structures, and the CbC reporting requirements, combined with the automatic exchange of information, will afford the tax authorities opportunities for better review of the operations of multinational groups.

Under the CbC rules, each ultimate parent entity of a multinational enterprise (MNE) group that is a tax resident of Barbados must file a CbC report. The legislation defines the terms “ultimate parent entity” and “constituent entity” as well as which entities constitute MNE groups and which are “excluded MNE groups.”

The CbC rules further provide that:

  • A CbC report is to be filed with the Competent Authority (in Barbados, the Minister of Finance) no later than 12 months after the last day of the reporting fiscal year of the MNE group. The first reporting fiscal year is any fiscal year beginning on or after 1 January 2021.
  • Each reporting entity must establish and keep certain records about the CbC report for a five-year period.
  • The contents of the report and the method of reporting are pending (but based on the legislation, it appears that an electronic filing method may be specified).
  • A failure to comply with the CbC reporting obligations can be subject to various penalties.

Read a January 2022 report [PDF 3.3 MB] prepared by the KPMG member firm in Barbados


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