Cayman eases deadline for CbC Reporting

Authorities in the Cayman Islands have pushed back the deadline for notifying local authorities of which entity will file a country-by-country (CbC) report, and for filing the first reports.

On February 2, 2018, the extensions were announced as well as a confirmation was made that in early March 2018 CbC reporting guidance will be released and the Cayman CbC reporting portal will be launched.

Under the notification obligation, the reporting entity of an MNE Group with constituent entities resident in the Cayman Islands must appoint the individuals as the “Primary Contact” and the “Secondary Contact” for those constituent entities. The Primary Contact may be an agent of the reporting entity while the Secondary Contact must be a fiduciary or management-level employee of the Reporting Entity. Neither the Primary Contact, nor the Secondary Contact must be resident in Cayman.

The CbC Report must be made via the CbCR Portal by uploading an XML file in the format prescribed by the OECD.

The CbC report is one element of a new 3-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework, MNEs are required to provide aggregate information annually for each jurisdiction where they do business, relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group. The reporting covers information on entities doing business in a particular jurisdiction as well as the business activities each entity engages in.

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