The Guernsey Government has published the competent authority agreement on the automatic exchange of Country-by-Country (CbC) Reports with Hong Kong, which was signed on 9 January 2019. The agreement is effective the date it was signed
The agreement provides that pursuant to Article 24 (Exchange of Information) of the 2013 Guernsey-Hong Kong tax treaty, each Competent Authority will annually exchange on an automatic basis the CbC Report received from each reporting entity that is resident for tax purposes in its jurisdiction with the other competent authority, 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 jurisdiction of the other competent authority.
The agreement is limited in the reporting fiscal years covered, including that with respect to fiscal years beginning between 1 January 2017 and 31 December 2018, CbC reports are to be exchanged as soon as possible and no later than 15 months after the last day of the fiscal year of the MNE Group to which the CbC report relates. For fiscal years beginning on or after 1 January 2019, the exchange of CbC reports will be provided for under the CbC MCAA (first year CbC MCAA is effective for Hong Kong).
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