Guernsey and the UK have signed a bilateral competent authority agreement on the exchange of Country-by-Country (CbC) reports. The agreement was signed by the UK on 24 November 2017 and by Guernsey on 29 November and 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 agreement provides that pursuant to Article 5A (Automatic Exchange of Information) of the Guernsey-UK tax information exchange agreement, as amended, 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.

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.