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Guernsey consultation on the introduction of Country by Country Reporting

Country by Country Reporting

Guernsey is committed to working with other countries and jurisdictions to reach a globally fair and modern international tax system.


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The OECD Base Erosion and Profit Shifting (BEPS) project aims to realign taxation with economic substance and value creation, while preventing double taxation. Guernsey has pledged to support the project and is an active participant, collaborating with over 100 other countries and jurisdictions to implement the measures developed to tackle BEPS.

Under Action 13 (Transfer Pricing Documentation and Country by Country Reporting) of the OECD’s Action Plan, Country by Country Reporting (CbCR) is one of the four minimum standards expected to address BEPS.

CbCR requires that multinational groups over a certain size (consolidated group revenue of EUR 750 million or more) report specified data on their international operations to their tax authority. This information is then disseminated to other jurisdictions in which the group operates with which the tax authority has an agreement to exchange such information. 

On Friday 23 September 2016, the States of Guernsey Policy & Resource Committee released a consultation on the introduction of CbCR in Guernsey; the consultation runs until Friday 21 October 2016. Given the threshold, only a handful of Guernsey institutions will be impacted when CbCR becomes live and it is important that these groups are aware of their obligations in this regard.

Please click here for a map that shows the current status summary of CbCR country implementation. What is clear to see is that for a third country, Guernsey is fully engaged in the process to support the BEPS initiative.

KPMG in the Channel Islands can provide you with further insight into how Channel Island businesses will be impacted by CbCR and other related international developments now and in the future.

© 2020 KPMG Channel Islands Limited, a Jersey company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

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