Seychelles has implemented Country-by-Country (CbC) Reporting regulations in line with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 framework, which aims to enhance tax transparency among large multinational enterprises (MNEs).

Key Features of the Regulations

• Applicability: The regulations apply to MNE groups with consolidated group revenue of at least EUR 750 million and where the ultimate parent entity is resident in Seychelles.
• Filing Requirements: The ultimate parent entity must file a CbC report with the Seychelles Revenue Commission within 12 months after the end of its tax year, starting with tax years ending December 2019 and annually thereafter.
• Content of the Report: The CbC report must include, for each jurisdiction where the MNE operates:
  • Revenue
  • Profit or loss before income tax
  • Income tax paid and accrued
  • Share capital
  • Accumulated earnings
  • Number of employees
  • Tangible assets (excluding cash or cash equivalents)
  • Identification of each constituent entity, its tax residence, and place of incorporation.
• Secondary Filing: If a Seychelles-resident entity is not the ultimate parent, it must disclose to the tax authority which entity is the reporting entity and its tax residence.
• Exchange of Information: Seychelles has joined the Multilateral Competent Authority Agreement on the Exchange of CbC Reports, enabling the automatic exchange of CbC reports with other tax authorities globally.

Legislative Updates in 2021

While the main CbC reporting obligations were introduced in 2019, the Business Tax (Amendment of Schedules) Regulations, 2021 (S.I. 108 of 2021), effective from January 1, 2022, amended the tax rates and schedules under the Business Tax Act but did not specifically alter the CbC reporting framework. The 2021 amendments focused on tax rates for various entities rather than reporting obligations.

International Context

Seychelles’ CbC reporting regime aligns with international standards, requiring the disclosure of key financial and operational information by large MNEs to tax authorities for use in transfer pricing and BEPS risk assessments. The information is exchanged with other jurisdictions to support global tax compliance and transparency efforts.