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Seychelles Publishes Regulations for CbC Reporting

On 23 April 2019, Seychelles published Statutory Instrument 25 of 2019 in the Official Gazette, which contains the Revenue Administration (Country-by-Country Reporting Multinational Enterprise groups) Regulations, 2019. The key aspects of the regulations are as follows:

  • The CbC reporting requirement applies for reporting tax years ending on or after 31 December 2019 for MNE groups meeting the standard EUR 750 million consolidated group revenue threshold in the preceding year;
  • Only ultimate parent entities resident in Seychelles are required to file a CbC report;
  • All group constituent entities resident in Seychelles are required to notify the Commissioner General whether it is the ultimate parent and, if not, must notify the Commissioner General of the identity and tax residence of the group's reporting entity;
  • For the reporting tax year ending 31 December 2019, the notification is due within 3 months following the end of the year, and for subsequent years, the notification is due by the end of the reporting tax year;
  • For the reporting tax year ending 31 December 2019 and subsequent years, the CbC report is due within 12 months following the end of the reporting tax year;
  • A penalty of SCR 20,000 will be imposed on persons who:
    • fail to comply with the CbC reporting regulations;
    • knowingly provide inaccurate information when filing a CbC report; or
    • identify inaccuracies after submitting a CbC report and fail to take reasonable steps to inform the Commissioner General within the specified time (no later than 3 months after becoming aware of an error).

The regulations also include a schedule that contains the standard CbC report table templates, which are to be followed when filing a CbC report.

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