Mauritius Finalizes CbC Reporting Regulations
Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation.
The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework, MNEs are required to provide aggregate information annually for each jurisdiction where they do business, relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group. It also covers information about which entities do business in a particular jurisdiction and the business activities each entity engages in.
Mauritius’s regime follows the OECD’s guidance. The parent entity of a multinational group must report under the framework if its total consolidated group revenue exceeds the local currency equivalent of EUR750m (currently MUR30.62bn). In certain circumstances a surrogate parent entity can file a report in Mauritius in respect of a group tax resident in another territory.
The regulations will apply to fiscal years beginning on or after July 1, 2018. The CbC report and the notification of which entity is the filing entity are due within 12 months from the last day of a company’s fiscal year.
Forms are included in an annex to the Regulations.