The Government of Bermuda has issued an updated tax guidance to assist businesses on complying with Bermuda’s country-by-country (CbC) reporting requirement.
CbC reporting is part of a three-tiered approach to transfer pricing documentation (along with “master” and “local” files) developed under base erosion and profit shifting Action 13.
In Bermuda, CbC reporting regulations apply to MNE Groups having total consolidated group revenue of over EUR750m. CbC reports need to be filed in respect of accounting periods starting on or after January 1, 2016, for MNE Groups that are in scope.
The updated guidance – published on July 26 – is intended to aid businesses that are required to report information under the Bermuda CbC reporting legislation. It is also intended as a reference source for Bermuda Constituent Entities, legal and tax professionals for use alongside the Bermuda CbC reporting legislation, and OECD core documents.
According to the guidance, a relevant Bermuda Constituent Entity must apply the Bermuda CbC reporting legislation in force at the time, with reference to any OECD explanatory materials for CbC reporting and the guidance, as applicable.