Barbados has implemented Country-by-Country Reporting (CbCR) as part of its commitment to the OECD Base Erosion and Profit Shifting (BEPS) Action 13 framework. The Barbados Revenue Authority (BRA) oversees the implementation and compliance of CbCR regulations in the country. These measures aim to enhance tax transparency and prevent profit shifting by multinational enterprises (MNEs).

This guide provides CFOs and tax professionals with a structured overview of Barbados’ CbCR framework, including applicability, reporting obligations, submission process, penalties, and key resources.

Applicability of CbCR in Barbados

Criteria for Reporting

CbCR obligations apply to multinational enterprise (MNE) groups that:

• Have consolidated annual revenue of at least BBD 1.5 billion (equivalent to EUR 750 million) in the preceding financial year.
• Include at least one entity or permanent establishment (PE) in Barbados.

Local Filing Requirements

A Barbados entity must file a CbC report if:

• It is the Ultimate Parent Entity (UPE) of the MNE group.
• It has been designated as the Surrogate Parent Entity (SPE) for CbCR purposes.
• The UPE is in a jurisdiction that does not require CbCR or does not have a qualifying exchange agreement with Barbados.

Relevant Legislation

• Income Tax (Country-by-Country Reporting) Act, 2021 – Establishes Barbados’ CbCR framework.
• OECD BEPS Action 13 – Provides the international standard for CbCR requirements.

Reporting Requirements

Content of the CbC Report

The CbC report must contain jurisdictional financial data, including:

• Total revenues (from related and unrelated party transactions).
• Profit or loss before income tax.
• Income tax paid and accrued.
• Stated capital and retained earnings.
• Number of employees.
• Tangible assets, excluding cash or cash equivalents.

Notification Requirement

• All Barbados entities within an MNE group must notify the BRA regarding which entity will file the CbC report and in which jurisdiction.
• The notification must be submitted electronically before the end of the financial year.

Submission Platform

• Reports must be electronically filed via the BRA’s CbCR Portal, using the OECD CbCR XML schema.

Resource

Filing instructions and guidelines are available on the Barbados Revenue Authority website:
Barbados Revenue Authority – CbCR

Filing Deadlines

• CbC Reports: Must be filed within 12 months after the end of the financial year.
  • Example: For a financial year ending 31 December 2023, the report must be submitted by 31 December 2024.
• Notifications: Must be filed before the end of the financial year.

Penalties for Non-Compliance

Penalties and Consequences

Failure to comply with Barbados’ CbCR requirements may result in:

• Fines of up to BBD 100,000 for failure to submit or inaccurate reporting.
• Additional penalties for persistent non-compliance.
• Increased scrutiny from the BRA, leading to potential tax audits.

Mitigation Measures

• Companies can apply for extensions or appeal penalties if they can demonstrate reasonable cause for non-compliance.

Confidentiality and Data Exchange

Data Protection

• The BRA ensures that CbC reports remain confidential and are only used for tax risk assessment purposes.
• Reports are automatically exchanged with jurisdictions that have a bilateral exchange agreement with Barbados.