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Prestigious speakers flying in for Early Years Conference
Thursday 17 August 2017

Parents and professionals working with young children will have the chance to hear from leaders in the field of Early Years education at a special one day conference being hosted in Guernsey on 2nd September.

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Yemen Crisis - Cholera outbreak in Yemen hits grim threshold
Thursday 17 August 2017

In December 2016, the UK Disaster Emergency Committee ("the DEC") launched an appeal in response to the growing humanitarian crisis in Yemen. At that time, the Overseas Aid & Development Commission donated £50,000 to the appeal.

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A Level, IB and Level 3 Results 2017
Thursday 17 August 2017

Congratulations to all students who have achieved a fantastic set of A Level, International Baccalaureate and Level 3 results this year. 237 A Level students and 107 Level 3 students received their results today. IB results were released a few weeks ago (17 students).

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Coming soon – a map of events, hazards and other useful information
weather iconFair, some cloudier spells this evening. Risk of a shower.
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weather iconFair, some cloudier spells this evening. Risk of a shower.
High-°CLow15°C
5 day forecastTide timetables


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Caribbean Pr Southampton 06:00  


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ChannelChief Jersey 07:15  
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Arrival


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Mail/Newspapers06:302017-08-18MailNPT22G


Departure


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Aurigny06:502017-08-18ManchesterGR670
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Base Erosion and Profit Shifting (BEPS) & Country by Country Reporting (CbCR)

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  • Useful links to relevant material

  • What is the Country by Country reporting regime?

    • Country-by-country reporting is one of four minimum standards under the OECD Base Erosion and Profit Shifting (BEPS) project that aims to improve transparency between multinational businesses and tax authorities, and to help identify aggressive tax avoidance.
    • Under country-by-country reporting, multinational groups with consolidated group revenue of EUR 750 million or more, are required to report specified data on their international operations to their tax authority annually ("full reporting"), in respect of accounting periods commencing on or after 1 January 2016. That tax authority will in turn disseminate relevant information to jurisdictions with which it has an agreement to exchange such information.
    • Present indications are that due to the current revenue threshold level involved, only a handful of Guernsey entities will be impacted by the introduction of country by country reporting. A consultation on the introduction of country by country reporting in Guernsey was undertaken in October 2016.
    • A secondary aspect of the country-by-country reporting regime requires the separate business units of multinational groups ("MNEs") to provide notification to the tax authority annually as a constituent entity if:
      • they are included in the consolidated financial statements of an MNE for financial reporting purposes, or would be so included if equity interests in such business unit were traded on a public securities exchange;
      • they are excluded from the MNE's consolidated financial statements solely on size or materiality grounds; and
      • they are a permanent establishment of (a) or (b) for which separate financial statements are prepared.
  • Who is responsible for submitting full reports - the reporting entity?

    • Broadly the ultimate parent entity of a qualifying multinational group ("MNE") must file, to their tax authority, the relevant CbCR Report on the group's behalf. It is, however, possible for the MNE Group to elect for a different constituent entity to do the reporting (making that entity a "surrogate parent entity").
  • Format required for Country by Country reporting (full reports)

    • The Director of Income Tax will require that CbCR full reports are made using a web based reporting tool called the Information Gateway Online Reporter (IGOR), further information concerning the use of IGOR will be added to this webpage in due course.
    • The format of the full CbC reporting will be required in an XML format using the schema provided by the OECD, details of which can be found on the following webpage: https://www.oecd.org/tax/automatic-exchange/about-automatic-exchange/country-by-country-reporting-xml-schema-user-guide-for-tax-administrations-and-taxpayers.htm
    • If an entity is part of a multinational group with consolidated group revenue of EUR 750 million or more, there will be a CbCR Reporting requirement, therefore, it will be necessary for that entity to know who the reporting entity for the group is.
  • If an entity is not a reporting entity, are there any other filing requirements under country by country reporting?

    • Yes. An entity must notify the Director by 30th November in the year following the last day of the accounting period if it is a constituent entity. Details of the reporting entity for the multinational group, together with the country of tax residence for the reporting entity and their accounting period end must also be provided.
    • This notification should be given annually on the company tax return. The first report will be required in respect of accounting periods commencing on or after 1 January 2016.
    • If an entity is unsure whether it is a constituent entity, it should contact its parent entity or ultimate parent entity.
  • What is a constituent entity?

    • Separate business units of multinational groups ("MNEs") are a constituent entity if:
      • they are included in the consolidated financial statements of an MNE for financial reporting purposes, or would be so included if equity interests in such business unit were traded on a public securities exchange;
      • they are excluded from the MNE's consolidated financial statements solely on size or materiality grounds; and
      • they are a permanent establishment of (a) or (b) for which separate financial statements are prepared.
    • If an entity is unsure whether it is a constituent entity, it should contact its parent entity or ultimate parent entity.
  • If an entity is dual resident, what constituent entity notification is required in Guernsey?

    • Dual resident entities will not be required to notify the Director annually that they are a constituent entity, where they are deemed resident in the other territory by virtue of a double taxation arrangement, and they are filing a constituent entity notification in that other territory.
  • BEPS Action 5 - Spontaneous exchange of rulings

    • Circular issued on 8th June 2017 to GSCCA and Guernsey Bar Council pdf icon Rulings - BEPS Action 5 [264kb]
    • Application for a Guernsey Tax Ruling msword icon Form 702 [89kb].
    • Please ensure that all completed applications are emailed to EOI@gov.gg with the subject header "BEPS Action 5 Tax Ruling Application".

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