Seychelles publishes country-by-country reporting regulations

The government of Seychelles on April 23 published country-by-country reporting regulations in the Supplement to the Official Gazette

Statutory Instrument 25 of 2019 requires multinationals with consolidated group revenue of EUR 750 million or more that have an ultimate parent entity resident in Seychelles to file with the Seychelles revenue authorities a report within 12 months after its tax year ending December 2019 and after that every 12 months after that.

The report must outline the MNEs revenue, profit, loss before income tax, income tax paid, income tax accrued, share capital, accumulated earnings, number of employees, and tangible assets other than cash or cash equivalents for each jurisdiction in which the MNE group operates. The report must also contain information identifying each constituent entity of the MNE group, setting out the group members’ tax residence and location of incorporation.

The regulations also require constituent entities resident in Seychelles that are not ultimate parent entities to disclose to the tax authority which entity is the reporting entity and the tax residence of that entity.

Seychelles has entered into the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports and expects to exchange the information with other countries’ tax administrations.