Organization : Department For International Tax Cooperation (DITC)
Facility : Country-by-Country Reporting (CbCR)
Country : Cayman Islands
Website : https://www.ditc.ky/cbcr/
What is Country-by-Country Reporting (CbCR)?
Country-by-Country Reporting (CbCR) is part of Action 13 of the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS). CbCR requires multinational enterprises (MNEs) that meet certain criteria to file a country-by-country report (CbC Report) with tax administrations or tax authorities. The CbC Report provides a breakdown of the amount of revenue, profits, taxes and other indicators of economic activities for each tax jurisdiction in which the MNE Group does business.
Related / Similar Facility : DITC Common Reporting Standard (CRS) Cayman Islands
FAQ On Country-by-Country Reporting (CbCR)
Frequently Asked Questions FAQ On Country-by-Country Reporting (CbCR)
Do I have to submit a Notification each year?
No, this is a one-off process.
How do I update my Notification to show the correct UPE / SPE details?
The Primary Contact should email the DITC Portal Team and provide details of the new UPE / SPE.
How do I update my Constituent Entity list?
The Primary Contact should login to the DITC Portal and upload an amended Constituent Entities File (CSV) .
Who is required to submit a CbCR Report?
A Reporting Entity (UPE or SPE) must be resident in the Islands in order to make a CbC Report for its MNE Group via the DITC Portal.
What Multinational Enterprises are in scope for CbCR?
CbCR only applies to MNE Groups with annual consolidated group revenue of not less than a specified threshold amount in the preceding fiscal year. The Cayman Islands has specified the threshold as US$850 million, but other jurisdictions may specify the threshold in Euros (€750 million). Further information can be found in the Cayman CbCR Guidelines.
What is the Reporting deadline for CbCR?
The deadline for Reporting in respect of any subsequent Fiscal Year is within 12 months of the end of that relevant Fiscal Year.
When can I submit my CbC Report?
The standard filing deadline is 12 months after the last day of the reporting fiscal year. Please refer to the 3 December 2025 Industry Advisory extension notice for MNE Groups with a filing deadline between 31 July 2025 and 31 December 2025. These MNE Groups will be granted an extension for submitting their 2024 fiscal year filings only. The new deadline is 27 February 2026.
Can I submit test returns?
Testing is not permitted within the DITC Portal.
What information should be included in my CbC Report?
The CbC Report provides a breakdown of the amount of revenue, profits, taxes and other indicators of economic activities for each tax jurisdiction in which the MNE Group does business. Please refer to the OECD CbCR XML Schema User Guide for Tax Administrations (User Guide v2.0 June 2019) as well as the Cayman Islands CbC XML Schema – User Guide and CbC XML Schema v2.0 Example for further details. These are also available on the DITC website.
Do you offer templates that may assist in completing my Notification and Reporting obligations?
Yes. The DITC offers a template for the Letter of Authorisation, Additional User File and Constituent Entities CSV File. Please refer to the Instructions on Constituent Entities File when completing the Constituent Entities CSV File. A sample XML file for reporting is also available on the DITC website together with the OECD CbCR XML Schema User Guide for Tax Administrations (User Guide v2.0 June 2019) and the Cayman Islands CbC XML Schema – User Guide. These provide guidance on creating XML files.
What is the Notification Deadline For CbCR?
The deadline for Notification, or to update an existing Notification in respect of any subsequent Fiscal Year, is before the end of that relevant Fiscal Year.