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Country-by-Country Reporting (CbCR)

COUNTRY-BY-COUNTRY REPORTING

Country-by-Country Reporting (CbCR) is an international tax transparency initiative developed by the Organisation for Economic Co-operation and Development (OECD) under Action 13 of the Base Erosion and Profit Shifting (BEPS) Project. CbCR requires large multinational enterprise (MNE) groups to provide tax authorities with high-level information on the global allocation of income, taxes paid, and certain indicators of economic activity across the jurisdictions in which they operate.

Bermuda adopted the OECD's Country-by-Country Reporting regime in 2016 as part of its commitment to international tax transparency and cooperation. Reporting requirements apply to qualifying multinational enterprise groups with annual consolidated group revenue of at least €750 million in the preceding fiscal year.

To give effect to CbCR, Bermuda amended the International Cooperation (Tax Information Exchange Agreements) Act 2005 and the USA-Bermuda Tax Convention Act 1986. In addition, Bermuda enacted the International Cooperation (Tax Information Exchange Agreements) Country-by-Country Reporting Regulations 2017 and the USA-Bermuda (Country-by-Country Reporting) Regulations 2017.

Under Bermuda's CbCR legal framework, Ultimate Parent Entities (UPEs) that are resident in Bermuda for tax purposes, and certain Surrogate Parent Entities (SPEs), may be required to submit a Country-by-Country Report to the Competent Authority. The CbC Reports are exchanged with partner jurisdictions in accordance with applicable international agreements and confidentiality safeguards. Please note below the list of Reportable Jurisdictions.

A CbC Report generally includes information relating to:

Revenue;
Profit (or loss) before income tax;
Income tax paid and accrued;
Stated capital and accumulated earnings;
Number of employees;
Tangible assets; and
Constituent entities of the MNE Group, including the entities’ jurisdiction of tax residence, TINs, addresses, and business activities

All qualifying multinational enterprise groups are required to register with the Corporate Income Tax Agency, as Competent Authority via the Bermuda Tax Information Reporting Portal Login.

The portal user guide can be accessed here.

KEY DEADLINES

The CbC Report is due twelve months after the last day of the reporting fiscal year of the MNE Group.

LEGISLATION

GUIDANCE

HISTORICAL GUIDANCE