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Barbados: Guidance on top-up tax regime and GIR return filings

Various guidance items to assist taxpayer with GIR return filings

August 3, 2026

The Barbados Revenue Authority (BRA) issued the following items of guidance related to the top-up tax regime and global anti-base erosion (GloBE) information return (GIR) filings:

  • Guidance Note OGC No.13/2026 issued on July 15, 2026, clarifying that the transitional qualified domestic minimum top-up tax (QDMTT) for fiscal year 2024 applies only when the income of a Barbados domestic minimum top-up tax (DMTT) group is subject to an income inclusion rule (IIR) or undertaxed profits rule (UTPR) in another jurisdiction. The guidance explains that when Barbados constituent entities (CEs) are subject to an IIR through an intermediate parent entity, the QDMTT may apply, whereas entities not subject to an IIR or UTPR outside Barbados are excluded for fiscal year 2024.
  • Guidance Note OGC No. 9/2026 issued on June 29, 2026, confirming that qualifying entities with a December 31, 2024, tax year-end will not incur penalties or interest for the late filing of corporation top-up tax notifications and GIRs if submitted on or before July 31, 2026, although the original filing deadline remains June 30, 2026.
  • Announcements issued on June 19, 2026, stating that GIR notifications and direct filings must be made through the upgraded AEOI portal, while local top-up tax payments can be made through TAMIS. The announcements specify that payments must be made using the newly introduced "Top Up Tax First Year" tax type.
  • Competent Authority (CA) regulations issued on June 17, 2026, by the Minister of Finance, designating the BRA as the CA for exchanging GIRs. The regulations, which became effective on January 1, 2026, include rules on filing exemptions, extensions, corrections, information exchange, tax assessments, and the general 15-month filing deadline for GIRs.
  • Guidance notes issued on June 11, 2026, to assist multinational enterprise groups with corporation top-up tax compliance ahead of the June 30, 2026, filing and payment deadline, covering country-by-country (CbC) reporting transitional safe harbors, de minimis exclusions, the QDMTT safe harbor, and GIR and foreign filing notifications.


For more information, contact a tax professional with the KPMG member firm in Barbados:

Marianne Greenidge | mariannegreenidge@kpmg.bb

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