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New CbC Reporting Obligations In Seychelles From 2020

by Lorys Charalambous, Lowtax.net, Cyprus
05 June, 2019

Seychelles has gazetted legislation for the introduction of new country-by-country reporting obligations that multinational entities will be required to comply with starting in 2020.

In line with the OECD's recommendations in this area, multinational groups whose group gross consolidated turnover was EUR750m (USD843m) or greater in the preceding tax year must file a CbC report within 12 months of the end of any tax year ending December 31, 2019, or thereafter.

In addition, within three months of the end of that tax year, the group should report whether an entity resident for tax purposes in Seychelles is the ultimate parent entity of the group. If not, the entity must identify the UPE and the jurisdiction in which it is registered for tax and will file a CbC report.

A penalty of SCR20,000 (USD1,467) applies for those taxpayers who fail to comply with the new requirements. The penalty applies for wilful non-compliance, failure to correct errors or omissions in CbC reports filed, or for making false statements in CbC reports.

The regime has been transposed into domestic law via the Revenue Administration (Country-by-Country Reporting Multinational Enterprise Groups) Regulations, 2019 (Statutory Instrument 25 of 2019), published in the Official Gazette on April 23, 2019.

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