The Bahamas, an archipelagic state in the Caribbean, has implemented Country-by-Country (CbC) Reporting through the Commercial Entities (Substance Requirements) Regulations, 2018.

MNEs with a consolidated group revenue of at least USD 850 million in the previous fiscal year are required to file a CbC report. The report should be in XML format and should contain information on the global allocation of income, taxes paid, and other indicators of economic activity among tax jurisdictions in which the MNE group operates.

The ultimate parent entity of the MNE group is responsible for filing the CbC report if it is resident in The Bahamas. If the ultimate parent entity is not resident in The Bahamas, the obligation to file the CbC report falls on the surrogate parent entity, if any, that is resident in The Bahamas.

The deadline for filing the CbC report in The Bahamas is within 12 months from the end of the fiscal year of the MNE group. For example, if the fiscal year of the MNE group ends on December 31, the CbC report must be filed by December 31 of the following year. Failure to file the CbC report or providing false or misleading information can result in penalties.

The Bahamas requires MNEs to file the CbC report electronically through the Bahamas Financial Services Board (BFSB) online portal. The BFSB is responsible for the collection and dissemination of the CbC report in The Bahamas. MNEs must register with the BFSB and obtain a unique user ID and password to access the online portal.

In addition to the CbC report, The Bahamas requires MNEs to submit a notification to the BFSB providing the name and address of the reporting entity, the tax jurisdiction of the reporting entity, and the identity and tax jurisdiction of the ultimate parent entity. The notification must be submitted within 6 months from the end of the fiscal year of the MNE group.

The Bahamas has also introduced economic substance requirements for entities that carry out certain activities in the jurisdiction. The economic substance requirements apply to entities engaged in banking, insurance, fund management, financing, leasing, headquarters, shipping, and intellectual property.

In summary, The Bahamas follows the guidelines set out by the OECD for CbC Reporting. MNEs meeting the threshold of consolidated group revenue must file a CbC report in XML format through the BFSB’s online portal within 12 months from the end of the fiscal year of the MNE group. Failure to comply with the CbC Reporting requirements can result in penalties. MNEs must also submit a notification to the BFSB within 6 months from the end of the fiscal year of the MNE group.