📘 Income Tax (Country-by-Country Reporting) Act, 2021-27
The Income Tax (Country-by-Country Reporting) Act, 2021-27 ("the Act") came into force on 31 December 2021 and implements Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. The legislation establishes a mandatory country-by-country (CbC) reporting regime in Barbados for large multinational enterprise (MNE) groups.
Under the Act, a CbC report must be filed where:
- the total consolidated group revenue for the previous fiscal year is at least USD 850 million (approximately BBD 1.72 billion); and
- the group has constituent entities or operations in two or more jurisdictions.
The ultimate parent entity (UPE) of the MNE group, if resident in Barbados, is required to file the CbC report with the Barbados Revenue Authority ("the Authority") within 12 months of the end of the reporting fiscal year.
A secondary reporting obligation may arise for a Barbados-resident constituent entity where the UPE is not resident in Barbados and any of the following conditions apply:
- the UPE is not required to file a CbC report in its jurisdiction of tax residence;
- the jurisdiction of the UPE has a valid international agreement with Barbados for the automatic exchange of tax information, but no exchange arrangement is in place by the filing deadline for the CbC report; or
- there has been a systemic failure by the UPE’s jurisdiction to exchange CbC reports, and the Authority (the Commissioner) has formally notified the constituent entity of this failure.
In circumstances where two or more constituent entities of the same MNE group are resident in Barbados, one may be appointed as a surrogate parent to file the report on behalf of all resident entities. The surrogate must notify the Authority in writing by the end of the reporting fiscal year. A Barbados-resident constituent entity is not required to file locally if a surrogate parent in another jurisdiction files the CbC report and certain conditions are met, including compliance with effective exchange agreements, and proper notification to the Authority.
All Barbados-resident constituent entities must notify the Authority of their reporting status, whether as ultimate parent, surrogate, or otherwise, no later than the last day of the reporting fiscal year.
The Act also empowers the Authority to exchange CbC reports with other jurisdictions under the Multilateral Competent Authority Agreement (CbC MCAA), subject to confidentiality safeguards.
Failure to comply with notification or reporting requirements may result in penalties, daily fines, and criminal sanctions, with appeal rights available through the Revenue Appeals Tribunal.
📥 Download the full Act(s) below:
Access the official documents in PDF format by clicking the links provided.