Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which it operates. In the case of Barbados, MNEs with annual consolidation group revenue equal to or higher than USD$850 Million in a fiscal year are required to prepare a CbC report. This CbC report is shared with tax administrations in these jurisdictions, for use in high-level transfer pricing and BEPS risk assessments.
Therefore, Barbados enacted the Income Tax (Country by Country Reporting) Act, 2021-27. The Act came into operation on the 31st day of December 2021. The first reporting fiscal year for the purposes of the Act is any fiscal year beginning on or after 1st day of January 2021.
Section 5 of the said Act provides that any constituent entity of an MNE Group that is resident for tax purposes in Barbados is required to notify the Barbados Revenue Authority whether it is the ultimate parent entity or the surrogate parent entity of the MNE Group no later than the last day of the reporting fiscal year of the MNE Group. In addition, were a constituent entity of an MNE Group that is resident for tax purposes in Barbados is not the ultimate parent entity nor the surrogate parent entity, it shall notify the Barbados Revenue Authority of the identity and tax residence of the reporting entity no later than the last day of the reporting fiscal year of the MNE Group.
Therefore, based on the above statutory provision, all resident constituent entities of a MNE Group are required to complete the notification form on an annual basis. To access the notification form visit the Global Relations Web Portal https://globalrelations.bra.gov.bb
To file a CbC report the MNE Group is required to register with the Barbados Revenue Authority (“the Authority”) via the Automatic Exchange of Information (“AEOI”) Web portal.