Wednesday, February 7, 2018
The Bermuda Government on January 31, 2018, updated the lists of the countries with which it will exchange country-by-country reports filed in Bermuda in 2018 and in 2019.
The Government has disclosed that it expects to exchange CbC reports with a total of 41 territories in 2018 relating to financial periods in 2016. This is an increase of seven territories since its last update in December 2017, when it had added five territories. These seven territories newly added are: Bulgaria, Colombia, Croatia, Hungary, Indonesia, Malta, and Romania (to be confirmed).
In 2019, it will exchange CbC reports filed in Bermuda with 45 territories. In its January 31, 2018, update, it added Brazil, Chile, Liechtenstein, and Uruguay.
The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the base erosion and profit shifting project. 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. It also covers information about which entities do business in a particular jurisdiction and the business activities each entity engages in.