Guernsey Seeks Feedback On CbC Reporting Framework

The States of Guernsey has launched a public consultation on implementing a new country-by-country reporting requirement for large corporations.

CbC reporting is a key element of the base erosion and profit shifting (BEPS) Action Plan and, if implemented in the territory, would require multinational enterprises incorporated in Guernsey with annual group revenues of EUR750m (USD837m) or more to file a detailed return annually with the territory's tax authorities.

The Government noted that the consultation forms the next stage in Guernsey's commitment to support the actions being taken under the BEPS project. As part of the consultation, the Government is asking for views on the following:

• Do you believe that Guernsey's CbC reporting legislation should be based on the OECD Model legislation?
• Should the fiscal level to identify an "excluded MNE group" be stated in Euros or Sterling?
• Under the Model legislation, it is envisaged that the tax authorities would impose penalties for failure to comply with the legislation. Is there any reason why the penalty regime should not be based on what will apply to the Common Reporting Standard?

Responses are requested by October 21, 2016.