As of the latest available information, Montserrat has not introduced formal legislation requiring Country-by-Country Reporting (CbCR) in accordance with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. However, multinational enterprise (MNE) groups with operations in Montserrat may still be impacted indirectly through CbCR obligations in other jurisdictions.

This guide provides an overview of the current status of CbCR in Montserrat, including regulatory context, implications for MNEs, and recommendations for proactive compliance.

Regulatory Context

• Legislation: There is no domestic legislation currently in force in Montserrat mandating CbCR disclosures.
• International Framework:
  • Montserrat is a British Overseas Territory and has not formally adopted the OECD Inclusive Framework on BEPS.
  • It does not participate in the Multilateral Competent Authority Agreement (MCAA) for the exchange of CbC reports.

Implications for Multinational Enterprises

• MNEs operating in Montserrat should ensure that relevant information on Montserrat operations is included in global CbC reports filed in other jurisdictions, particularly where the parent company is located.
• Local subsidiaries or branches in Montserrat may need to provide internal financial and operational data for inclusion in consolidated group reports.

Voluntary Compliance Recommendations

In the absence of formal local obligations, MNEs are advised to:

• Maintain complete and transparent intra-group transaction records.
• Follow OECD-aligned transfer pricing documentation standards.
• Stay informed on developments in international tax cooperation that may eventually extend to Montserrat.

Potential Developments

• As international pressure on tax transparency grows, Montserrat may adopt CbCR legislation in the future, particularly if required to align with UK or regional standards.
• MNEs with significant presence in Montserrat should monitor for any regulatory announcements from the local government or financial services regulators.

Useful Resources

• Montserrat Inland Revenue Department: https://www.gov.ms/taxation/
• OECD CbCR Guidance: https://www.oecd.org/tax/beps/country-by-country-reporting.htm
• UK HMRC CbCR Information (as applicable): https://www.gov.uk/guidance/country-by-country-reporting-in-the-uk