2 February 2018
The Cayman Islands has published the bilateral competent authority agreement on the exchange of Country-by-Country (CbC) reports signed with the United Kingdom on 4 December 2017. The agreement comes into effect on the date of the later of the notifications provided by each competent authority that its jurisdiction has the necessary laws in place to require reporting entities to file a CbC report (both already have CbC reporting requirements in place).
The arrangement provides that pursuant to Paragraph 13 (Exchange of Information and Tax Examinations) of the 2010 Cayman Islands-UK income tax arrangement, each competent authority will annually exchange on an automatic basis the CbC reports received from each reporting entity resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC report, one or more constituent entities of the MNE group of the reporting entity are resident for tax purposes in the jurisdiction of the other competent authority, or are subject to tax with respect to the business carried out through a permanent establishment situated in the other jurisdiction.
With respect to fiscal years beginning on or after 1 January 2016, CbC reports are to be exchanged as soon as possible and no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC report relates. With respect to subsequent fiscal years, reports are to be exchanged no later than 15 months after the last day of the fiscal year.
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