{"kind":"expression","expression":{"expr_id":"451","doc_id":"451","label":"SL 99 of 2017","is_as_enacted":"t","commenced_on":null,"superseded_on":null,"valid_from":null,"valid_to":null,"is_current":"t","incorporating":null,"akn_expr_iri":"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01","akn_envelope":"{\"_canary\": {\"iri\": {\"work\": \"\/akn\/ky\/act\/sl\/2017\/99\", \"expression\": \"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01\", \"manifestation\": \"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01.pdf\"}, \"pdf\": {\"md5\": \"f94491b303ea96101385de7599093a88\", \"path\": \"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2017\/2017-0099\/2017-0099_SL 99 of 2017.pdf\", \"pages\": 22, \"filename\": \"2017-0099_SL 99 of 2017.pdf\"}, \"errors\": [], \"extraction\": {\"model\": null, \"stats\": {\"word_count\": 6107, \"paragraph_count\": 24, \"text_char_count\": 41364}, \"usage\": null, \"method\": \"pymupdf-text\", \"version\": \"kyleg-akn-1.0\", \"extracted_at\": \"2026-06-22\"}, \"classification\": \"text_layer\", \"validation_flags\": [], \"docai_processor_id\": null}, \"akomaNtoso\": {\"act\": {\"body\": [{\"eId\": \"sec_n1\", \"num\": null, \"text\": \"Tax Information Authority Law TAX INFORMATION AUTHORITY (INTERNATIONAL TAX COMPLIANCE) (COUNTRY-BY-COUNTRY REPORTING) REGULATIONS, 2017 (SL 99 of 2017) SL 99 of 2017 PUBLISHING DETAILS Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 Arrangement of Regulations SL 99 of 2017 Tax Information Authority Law TAX INFORMATION AUTHORITY (INTERNATIONAL TAX COMPLIANCE) (COUNTRY-BY-COUNTRY REPORTING) REGULATIONS, 2017 (SL 99 of 2017) Arrangement of Regulations Regulation 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_20\", \"num\": \"20.\", \"text\": \"Arrangement of Regulations Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 21. 22.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_23\", \"num\": \"23.\", \"text\": \"SCHEDULE Standard template for Country-by-Country Report Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 Regulation 1 SL 99 of 2017 Tax Information Authority Law TAX INFORMATION AUTHORITY (INTERNATIONAL TAX COMPLIANCE) (COUNTRY-BY-COUNTRY REPORTING) REGULATIONS, 2017 (SL 99 of 2017) The Cabinet, in exercise of the powers conferred by section 25 of the Tax Information Authority Law (2017 Revision), makes the following Regulations \u2014\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_1\", \"num\": \"1.\", \"text\": \"Citation 1. These Regulations may be cited as the Tax Information Authority (International Tax Compliance) (Country-By-Country Reporting) Regulations, 2017.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_2\", \"num\": \"2.\", \"text\": \"Definitions 2. (1) In these Regulations \u2014 \u201cAuthority\u201d means the Tax Information Authority designated under section 4 of the Law, or a person designated by the Authority to act on behalf of the Authority; \u201cConsolidated Financial Statements\u201d means the financial statements of an MNE Group in which the assets, liabilities, income, expenses and cash flows of the Ultimate Parent Entity and the Constituent Entities are presented as those of a single economic entity; \u201cConstituent Entity\u201d means \u2014 Regulation 2 Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 (a) any separate business unit of an MNE Group that is included in the Consolidated Financial Statements of the MNE Group for financial reporting purposes, or would be so included if equity interests in such business unit of an MNE Group were traded on a public securities exchange; (b) any such business unit that is excluded from the MNE Group\u2019s Consolidated Financial Statements solely on size or materiality grounds; and (c) any permanent establishment of any separate business unit of the MNE Group included in (a) or (b) provided the business unit prepares a separate financial statement for such permanent establishment for financial reporting, regulatory, tax reporting, or internal management control purposes; \u201cExcluded MNE Group\u201d means, with respect to any Fiscal Year of the Group, a Group having total consolidated group revenue of less than eight hundred and fifty million United States Dollars during the Fiscal Year immediately preceding the Reporting Fiscal Year as reflected in its Consolidated Financial Statements for such preceding Fiscal Year; \u201cFiscal Year\u201d means an annual accounting period with respect to which the Ultimate Parent Entity of the MNE Group prepares its financial statements; \u201cGroup\u201d means a collection of enterprises related through ownership or control such that it is either required to prepare Consolidated Financial Statements for financial reporting purposes under applicable accounting principles or would be so required if equity interests in any of the enterprises were traded on a public securities exchange; \u201cInternational Agreement\u201d means the Multilateral Convention for Mutual Administrative Assistance in Tax Matters, any bilateral or multilateral Tax Convention or any Tax Information Exchange Agreement to which the Cayman Islands is a party and that, by its terms, provides legal authority for the exchange of tax information between jurisdictions including the automatic exchange of such information; \u201cMNE Group\u201d means any Group that \u2014 (a) includes two or more enterprises for which the tax residence is in different jurisdictions or includes an enterprise that is resident for tax purposes in one jurisdiction and is subject to tax with respect to the business carried out through a permanent establishment in another jurisdiction; and (b) is not an Excluded MNE Group; \u201cOECD Final Report\u201d means the document entitled \u201cTransfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report\u201d published by the Organization for Economic Co-operation and Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 Regulation 2 SL 99 of 2017 Development as part of the OECD\/G20 Base Erosion and Profit Shifting Project as may be amended from time to time; \u201cQualifying Competent Authority Agreement\u201d means an agreement that \u2014 (a) is between authorised representatives of those jurisdictions that are parties to an International Agreement; and (b) requires the automatic exchange of Country-by-Country Reports between the party jurisdictions; \u201cReporting Entity\u201d means the Constituent Entity which is required to file a Country-by-Country Report conforming to the requirements in regulation 6 in its jurisdiction of tax residence on behalf of the MNE Group and which may be the Ultimate Parent Entity or the Surrogate Parent Entity; \u201cReporting Fiscal Year\u201d means the Fiscal Year to which the operational results in the Country-by-Country Report (described in regulation 6) relate; \u201cresident in the Islands\u201d for a Constituent Entity means \u2014 (a) being incorporated or established in the Islands; (b) having a place of effective management in the Islands; or (c) being subject to financial supervision in the Islands; \u201cSurrogate Parent Entity\u201d means one Constituent Entity of the MNE Group that has been appointed by the MNE Group as a sole substitute for the Ultimate Parent Entity to file the Country-by-Country Report in that Constituent Entity\u2019s jurisdiction of tax residence on behalf of the said MNE Group when one or more of the conditions set out in regulation 4(2)(b) applies; \u201cSystemic Failure\u201d with respect to a jurisdiction means that the jurisdiction has a Qualifying Competent Authority Agreement in effect with the Cayman Islands, but has suspended automatic exchange (for reasons other than those that are in accordance with the terms of that Agreement) or otherwise persistently failed to automatically provide to the Cayman Islands Country-by Country Reports in its possession of MNE Groups that have Constituent Entities in the Cayman Islands; and \u201cUltimate Parent Entity\u201d means a Constituent Entity of an MNE Group that meets the following criteria \u2014 (a) it owns directly or indirectly a sufficient interest in one or more other Constituent Entities of the MNE Group such that it is required to prepare Consolidated Financial Statements under accounting principles generally applied in its jurisdiction of tax residence, or would be so required if its equity interests were traded on public securities exchange in its jurisdiction of tax residence; and Regulation 3 Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 (b) there is no other Constituent Entity of the MNE Group that owns directly or indirectly an interest described in paragraph (a) in the first mentioned Constituent Entity. (2) For the purposes of these Regulations, unless the context otherwise requires, the words \u201cjurisdiction of tax residence\u201d, \u201ctax residence\u201d and \u201cresident for tax purposes\u201d shall each be considered as incorporating a reference to \u201cresident in the Islands\u201d. (3) In these Regulations, a word or expression used in these Regulations and defined in the OECD Final Report but not in these Regulations has the meaning assigned to it in the OECD Final Report.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_3\", \"num\": \"3.\", \"text\": \"Effective date 3. These Regulations shall enter into force in the Islands on the date of publication and are effective for Reporting Fiscal Years of MNE Groups beginning on or after 1 January 2016.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_4\", \"num\": \"4.\", \"text\": \"Filing obligation 4. (1) Each Ultimate Parent Entity of an MNE Group that is resident in the Islands shall file with the Authority a Country-by-Country Report conforming to the requirements of regulation 6 with respect to its Reporting Fiscal Year on or before the date specified in regulation 6(3). (2) A Surrogate Parent Entity shall file with the Authority on or before the date specified in regulation 6(3) a Country-By-Country Report conforming to the requirements of these Regulations with respect to the Reporting Fiscal Year of an MNE Group of which it is a Surrogate Parent Entity if \u2014 (a) the entity is resident in the Islands; and (b) one of the following conditions applies \u2014 (i) the Ultimate Parent Entity of the MNE Group is not obligated to file a Country-By-Country Report in its jurisdiction of tax residence; (ii) the jurisdiction in which the Ultimate Parent Entity is resident for tax purposes has a current International Agreement to which the Cayman Islands is a party but does not have a Qualifying Competent Authority Agreement in effect to which the Cayman Islands is a party by the time specified in regulation 6(3) for filing the Report for the Reporting Fiscal Year; or (iii) there has been a Systemic Failure of the jurisdiction of tax residence of the Ultimate Parent Entity that has been notified by the Authority to the Constituent Entity resident in the Islands. Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 Regulation 5 SL 99 of 2017\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"Notification obligation 5. (1) Any Constituent Entity that is resident in the Islands shall notify the Authority of whether it is the Ultimate Parent Entity or the Surrogate Parent Entity no later than the last day of the Reporting Fiscal Year of the MNE Group except that such notification shall be filed by 31 March, 2018 with respect to the Reporting Fiscal Year of the MNE Group that began during 2016. (2) Where a Constituent Entity that is resident in the Islands is not the Ultimate Parent Entity nor the Surrogate Parent Entity, it shall notify the Authority of the identity and tax residence of the Reporting Entity no later than the last day of the Reporting Fiscal Year of such MNE Group except that notification under paragraph (1) shall be filed by 31 March, 2018 with respect to the Reporting Fiscal Year of the MNE Group that began during 2016.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Country-by-Country Report 6. (1) For the purposes of these Regulations, a Country-by-Country Report with respect to an MNE Group is a report containing \u2014 (a) aggregate information relating to the amount of revenue, profit (or loss) before income tax, income tax paid, income tax accrued, stated capital, accumulated earnings, number of employees and tangible assets other than cash or cash equivalents with regard to each jurisdiction in which the MNE Group operates; and (b) an identification of each Constituent Entity of the MNE Group setting out the jurisdiction of tax residence of such Constituent Entity and, where different from such jurisdiction of tax residence, the jurisdiction under the laws of which such Constituent Entity is organized and the nature of the main business activity or activities of such Constituent Entity. (2) The Country-by-Country Report shall be filed in a form identical to the standard template set out in Tables 1, 2 and 3 in Part 1 of the Schedule to these Regulations and the instructions contained in Part 2 of the Schedule shall apply. (3) The Country-by-Country Report required by these Regulations shall be filed no later than twelve months after the last day of the Reporting Fiscal Year of the MNE Group except that the Country-by-Country Report required with respect to the Reporting Fiscal Year that began on or before 31 March 2016 shall be filed no later than 31 March 2018.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"Use and Confidentiality of Country-by-Country Report Information 7. (1) The Authority shall use the Country-by-Country Report and any other information obtained pursuant to these Regulations for purposes of collaboration on compliance and enforcement with other Competent Authorities pursuant to a Qualifying Competent Authority Agreement. Regulation 8 Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 (2) The Authority shall preserve the confidentiality of the information contained in the Country-by-Country Report at least to the same extent that would apply if such information were provided to it under the provisions of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_8\", \"num\": \"8.\", \"text\": \"Compliance with notification and filing obligations 8. (1) A Constituent Entity shall comply with notification and filing obligations in the form and manner specified through use of the electronic portal or such other method as may be prescribed by the Authority. (2) The Authority shall notify Constituent Entities of the method of compliance with the notification and filing obligations by \u2014 (a) a post on an official website providing information generally; or (b) a notice given to a particular Constituent Entity. (3) Unless the contrary is proved, the Authority shall assume that a return that has been accepted by the electronic portal or such other method of compliance as may be prescribed \u2014 (a) has been made as required under paragraph (1); and (b) was made \u2014 (i) when the return was accepted by the portal or such other method of compliance as may be prescribed; (ii) by the person who made the return by using the portal; and (iii) with the authority of the Constituent Entity on whose behalf the return purports to have been made. (4) For the purposes of this regulation \u2014 \u201celectronic address\u201d includes an email address and the address of a digital mailbox; \u201celectronic portal\u201d means the Authority\u2019s electronic portal for the automatic exchange of information; and \u201cofficial website\u201d means \u2014 (a) the website of the Department for International Tax Cooperation; (b) a website of the Authority; or (c) any another Government website about international tax cooperation.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_9\", \"num\": \"9.\", \"text\": \"Guidance 9. The Authority may issue guidance for complying with these Regulations. Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 Regulation 10 SL 99 of 2017\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_10\", \"num\": \"10.\", \"text\": \"Compliance measures 10. (1) The Authority may, by notice given to a Constituent Entity, require the Constituent Entity \u2014 (a) to provide to the Authority, within a time specified by the Authority, any information, such information including a copy of a relevant book, document, electronically stored information or other record as may be in the Constituent Entity\u2019s possession or under its control that the Authority reasonably requires to determine the accuracy of information that the Constituent Entity gave to the Authority ; or (b) to make available to the Authority for inspection, at a time specified by the Authority, any book, document, electronically stored information or other record that is in the Constituent Entity\u2019s possession or under its control that the Authority reasonably requires to determine the accuracy of information provided by the Constituent Entity to the Authority. (2) If information the Authority requires for inspection or otherwise is outside of the Islands and the Authority requires the Constituent Entity to bring the information to the Islands, the Authority shall specify a time period that will enable the Constituent Entity to bring the information to the Islands and the Constituent Entity shall comply with the requirement of the Authority. (3) A Constituent Entity shall retain for six years any book, document, electronically-stored information or other record that relates to the information required to be reported to the Authority under these Regulations.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_11\", \"num\": \"11.\", \"text\": \"Arrangement to avoid obligation 11. If a person enters into an arrangement, a main purpose of which is to avoid an obligation under these Regulations, the arrangement, for the purposes of these Regulations, shall be deemed to be one which was not entered into and these Regulations shall have effect as if the arrangement had never been in existence.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_12\", \"num\": \"12.\", \"text\": \"Offence to contravene notification, reporting and monitoring regulations 12. A person commits an offence if that person contravenes regulations 4, 5, 6, 8 or 10.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_13\", \"num\": \"13.\", \"text\": \"Tampering 13. A person commits an offence if the person \u2014 (a) alters, destroys, mutilates, defaces, hides or removes information in a way that causes the person or anyone else to contravene these Regulations in relation to the information; or (b) authorizes, advises or counsels someone else to do anything referred to in paragraph (a). Regulation 14 Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_14\", \"num\": \"14.\", \"text\": \"Hindering 14. A person commits an offence if the person hinders the Authority in performing a function under these Regulations.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_15\", \"num\": \"15.\", \"text\": \"Reasonable excuse defence 15. (1) In proceedings against a person for an offence under these Regulations, it is a defence to prove that the person had a reasonable excuse. (2) Neither insufficiency of funds nor reliance on an agent or reliance on any other person is a reasonable excuse. (3) If a defendant had a reasonable excuse for committing an offence but the excuse ceases to exist, the defendant shall be considered as still having the reasonable excuse if the offence was remedied without undue delay after the excuse ceased to exist.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_16\", \"num\": \"16.\", \"text\": \"Punishment on summary conviction 16. Subject to regulation 17, a person who commits an offence under these Regulations is liable on summary conviction to a fine of ten thousand dollars or to imprisonment for a term of six months, or to both.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_17\", \"num\": \"17.\", \"text\": \"Authority\u2019s power to impose administrative penalty for offences 17. (1) The Authority may impose an administrative penalty of four thousand dollars where a person contravenes regulation 12, 13 or 14. (2) An administrative penalty imposed under this regulation shall be in accordance with the provisions in regulations 18 and 22. (3) Where the Authority decides to impose an administrative penalty it shall notify the person of its decision. (4) A notice under these Regulations may be in such form as the Authority determines and shall include the person\u2019s name, the reasons for imposing the penalty, the amount of the penalty and when it becomes due.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_18\", \"num\": \"18.\", \"text\": \"Administrative penalty not to apply 18. (1) Where a person is convicted in a court of law of an offence under these Regulations, that person shall not also be liable to an administrative penalty under these Regulations in relation to the same facts. (2) Where an administrative penalty is imposed under these Regulations, the person liable for that penalty shall not be subsequently or simultaneously charged with an offence under these Regulations in relation to the same facts. (3) Any administrative penalty payable under these Regulations may be recovered by the Crown in a court as a civil debt. Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 Regulation 19 SL 99 of 2017\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_19\", \"num\": \"19.\", \"text\": \"Daily default penalty 19. (1) A person who fails to pay the administrative penalty imposed under regulation 17 shall be liable to an additional penalty of an amount of two hundred dollars for each day during which the penalty imposed under regulation 17 remains unpaid. (2) Where the Authority decides to impose a daily default penalty it may only do so where it notifies the person who has failed to pay the administrative penalty of its decision. (3) A notice under these Regulations may be in such form as the Authority determines including the person\u2019s name, the reasons for imposing the penalty, the amount of the penalty and when it becomes or became due. 20. Administrative penalties for inaccurate information 20. (1) A person is liable to an administrative penalty of five thousand dollars, if \u2014 (a) the person provides inaccurate information when filing a Country-ByCountry Report; and (b) satisfies condition A or B in paragraphs (2) and (3). (2) Condition A is that the person knows of the inaccuracy at the time that the information is provided in the Report but does not inform the Authority of the inaccuracy at that time. (3) Condition B is that the person \u2014 (a) discovers the inaccuracy after the information is provided in the Report to the Authority; and (b) fails to take reasonable steps to inform the Authority of the inaccuracy.\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_21\", \"num\": \"21.\", \"text\": \"Matters to be disregarded in relation to liability to administrative penalties 21. (1) Liability to an administrative penalty under these Regulations does not arise if there is a reasonable excuse for the failure to comply with the relevant provisions or for the provision of inaccurate information. (2) For the purposes of this regulation, neither of the following is a reasonable excuse \u2014 (a) that there is an insufficiency of funds to do something; or (b) that a person relies upon another person to do something. (3) If a person had a reasonable excuse for a failure to comply but the excuse has ceased to exist, the person is to be treated as having continued to have the excuse if the failure is remedied without undue delay after the excuse had ceased to exist. Regulation 22 Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_22\", \"num\": \"22.\", \"text\": \"Imposition of administrative penalties 22. (1) If a person becomes liable to an administrative penalty under these Regulations, the Authority may impose the penalty in accordance with this regulation. (2) If the Authority intends to impose an administrative penalty, the Authority must notify the person of its intention and the notice must specify \u2014 (a) the Authority\u2019s reasons for holding the person liable to an administrative penalty; and (b) a reasonable period (which may not be less than fourteen days) within which the person to whom the notice is given may make representations to the Authority, and where such representations are made, the Authority shall take them into account in deciding whether to impose the administrative penalty. (3) An administrative penalty under regulation 17 or 19 may only be imposed within the period of twelve months beginning with the date on which the person became liable to the penalty. (4) An administrative penalty under regulation 20 may only be imposed \u2014 (a) within the period of twelve months beginning with the date on which the inaccuracy first came to the attention of the Authority; and (b) within the period of six years beginning with the date on which the person became liable to the penalty. (5) The Authority shall provide written reasons to the person on whom a penalty is imposed for any decision to impose an administrative penalty within a reasonable period of time of the decision. 23. Right of appeal 23. (1) A person upon whom an administrative penalty is imposed may, subject to this regulation, appeal against it to the Grand Court and such appeal shall act as a stay on the enforcement of the administrative penalty. (2) An appeal under this regulation may be made on questions of law or fact or both and the Grand Court may affirm or reverse the penalty or substitute its own penalty for that imposed by the Authority. (3) A person upon whom an administrative penalty is imposed may appeal it on the ground that liability to a penalty does not arise. (4) A person upon whom an administrative penalty is imposed may appeal against the amount imposed by the Authority. (5) For the avoidance of doubt, this regulation does not limit or otherwise affect any obligation of the person or Constituent Entity under these Regulations. Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SCHEDULE SL 99 of 2017 SCHEDULE (Regulation 6) Standard template for Country-by-Country Report Part 1 Table 1. Overview of allocation of income, taxes and business activities by tax jurisdiction Name of the MNE Group: Fiscal year concerned: Currency used: Tax Jurisdiction Revenues Profit (Loss) before Income Tax Income Tax Paid (on Cash Basis) Income Tax Accrued - Current Year Stated Capital Accumulated Earnings Number of Employees Tangible Assets other than Cash and Cash Equivalents Unrelated Party Related Party Total SCHEDULE Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 Please specify the nature of the activity of the Constituent Entity in the \u201cAdditional Information\u201d section. Tax Jurisdiction Table 2. List of all the Constituent Entities of the MNE Group included in each aggregation per tax jurisdiction Constituent Entities Resident in the Tax Jurisdiction Tax Jurisdiction of Organisation or Incorporation if Different from Tax Jurisdiction of Residence Research and Development Main Business Activity or Activities Holding or Managing  Intellectual Property Purchasing or Procurement Manufacturing or Production Sales, Marketing or Distribution Administrative, Management  or Support Services Provision of Services to  Unrelated Parties Internal Group Finance Regulated Financial  Services Insurance Holding Shares or Other  Equity instruments Dormant Other1 Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SCHEDULE SL 99 of 2017 Table 3. Additional Information Name of the MNE Group: Fiscal year concerned: Please include any further brief information or explanation you consider necessary or that would facilitate the understanding of the compulsory information provided in the Country-by-Country Report. Part 2 - General and Specific Instructions for Standard Template Country-byCountry Report A. General instructions 1. Purpose Table 1 to this Schedule contains a template for reporting a multinational enterprise\u2019s (MNE) group allocation of income, taxes and business activities on a tax jurisdiction-bytax jurisdiction basis. These instructions form an integral part of the model template for the Country-by-Country Report. 2. Definitions (a) Reporting MNE A Reporting MNE is the ultimate parent entity of an MNE group. (b) Constituent Entity For purposes of completing the Country-by-Country Report, a Constituent Entity of the MNE group is - (i) any separate business unit of an MNE group that is included in the Consolidated Financial Statements of the MNE group for financial reporting purposes, or would be so included if equity interests in such business unit of the MNE group were traded on a public securities exchange; (ii) any such business unit that is excluded from the MNE group\u2019s Consolidated Financial Statements solely on size or materiality grounds; and SCHEDULE Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 (iii) any permanent establishment of any separate business unit of the MNE group included in subparagraphs (i) or (ii) provided the business unit prepares a separate financial statement for such permanent establishment for financial reporting, regulatory, tax reporting, or internal management control purposes. (c) Treatment of Branches and Permanent Establishments The permanent establishment data should be reported by reference to the tax jurisdiction in which it is situated and not by reference to the tax jurisdiction of residence of the business unit of which the permanent establishment is a part. Residence tax jurisdiction reporting for the business unit of which the permanent establishment is a part should exclude financial data related to the permanent establishment. (d) Consolidated Financial Statements The Consolidated Financial Statements are the financial statements of an MNE group in which the assets, liabilities, income, expenses and cash flows of the ultimate parent entity and the Constituent Entities are presented as those of a single economic entity. 3. Period covered by the annual template The template should cover the fiscal year of the Reporting MNE. For Constituent Entities, at the discretion of the Reporting MNE, the template should reflect on a consistent basis either - (i) information for the fiscal year of the relevant Constituent Entities ending on the same date as the fiscal year of the Reporting MNE, or ending within the 12 month period preceding such date; or (ii) information for all the relevant Constituent Entities reported for the fiscal year of the Reporting MNE. 4. Source of data The Reporting MNE should consistently use the same sources of data from year to year in completing the template. The Reporting MNE may choose to use data from its consolidation reporting packages, from separate entity statutory financial statements, regulatory financial statements, or internal management accounts. It is not necessary to reconcile the revenue, profit and tax reporting in the template to the Consolidated Financial Statements. If statutory financial statements are used as the basis for reporting, all amounts should be translated to the stated functional currency of the Reporting MNE at the average exchange rate for the year stated in the \u201cAdditional Information\u201d section of the template. Adjustments need not be made, however, for differences in accounting principles applied from tax jurisdiction to tax jurisdiction. The Reporting MNE should provide a brief description of the sources of data used in preparing the template in the \u201cAdditional Information\u201d section of the template. If a Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SCHEDULE SL 99 of 2017 change is made in the source of data used from year to year, the Reporting MNE should explain the reasons for the change and its consequences in the \u201cAdditional Information\u201d section of the template. B. Specific instructions for standard template Country-by-Country Report 1. Overview of allocation of income, taxes and business activities by tax jurisdiction (Table 1) (a) Tax Jurisdiction In the first column of the template, the Reporting MNE should list all of the tax jurisdictions in which Constituent Entities of the MNE group are resident for tax purposes. A tax jurisdiction is defined as a State as well as a non-State jurisdiction which has fiscal autonomy. A separate line should be included for all Constituent Entities in the MNE group deemed by the Reporting MNE not to be resident in any tax jurisdiction for tax purposes. Where a Constituent Entity is resident in more than one tax jurisdiction, the applicable tax treaty \u201ctie breaker\u201d should be applied to determine the tax jurisdiction of residence. Where no applicable tax treaty exists, the Constituent Entity should be reported in the tax jurisdiction of the Constituent Entity\u2019s place of effective management. The place of effective management should be determined in accordance with the provisions of Article 4 of the OECD Model Tax Convention and its accompanying Commentary. (b) Revenues In the three columns of the template under the heading Revenues, the Reporting MNE should report the following information - (i) the sum of revenues of all the Constituent Entities of the MNE group in the relevant tax jurisdiction generated from transactions with associated enterprises; (ii) the sum of revenues of all the Constituent Entities of the MNE group in the relevant tax jurisdiction generated from transactions with independent parties; and (iii) the total of (i) and (ii). Revenues should include revenues from sales of inventory and properties, services, royalties, interest, premiums and any other amounts. Revenues should exclude payments received from other Constituent Entities that are treated as dividends in the payor\u2019s tax jurisdiction. (c) Profit (Loss) before Income Tax In the fifth column of the template, the Reporting MNE should report the sum of the profit (loss) before income tax for all of the Constituent SCHEDULE Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 Entities resident for tax purposes in the relevant tax jurisdiction. The profit (loss) before income tax should include all extraordinary income and expense items. (d) Income Tax Paid (on Cash Basis) In the sixth column of the template, the Reporting MNE should report the total amount of income tax actually paid during the relevant fiscal year by all the Constituent Entities resident for tax purposes in the relevant tax jurisdiction. Taxes paid should include cash taxes paid by the Constituent Entity to the residence tax jurisdiction and to all other tax jurisdictions. Taxes paid should include withholding taxes paid by other entities (associated enterprises and independent enterprises) with respect to payments to the Constituent Entity. Thus, if company A resident in tax jurisdiction A earns interest in tax jurisdiction B, the tax withheld in tax jurisdiction B should be reported by company A. (e) Income Tax Accrued (Current Year) In the seventh column of the template, the Reporting MNE should report the sum of the accrued current tax expense recorded on taxable profits or losses of the year of reporting of all the Constituent Entities resident for tax purposes in the relevant tax jurisdiction. The current tax expense should reflect only operations in the current year and should not include deferred taxes or provisions for uncertain tax liabilities. (f) Stated Capital In the eighth column of the template, the Reporting MNE should report the sum of the stated capital of all the Constituent Entities resident for tax purposes in the relevant tax jurisdiction. With regard to permanent establishments, the stated capital should be reported by the legal entity of which it is a permanent establishment unless there is a defined capital requirement in the permanent establishment tax jurisdiction for regulatory purposes. (g) Accumulated Earnings In the ninth column of the template, the Reporting MNE should report the sum of the total accumulated earnings of all the Constituent Entities resident for tax purposes in the relevant tax jurisdiction as of the end of the year. With regard to permanent establishments, accumulated earnings should be reported by the legal entity of which it is a permanent establishment. (h) Number of Employees Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SCHEDULE SL 99 of 2017 In the tenth column of the template, the Reporting MNE should report the total number of employees on a full-time equivalent (FTE) basis of all the Constituent Entities resident for tax purposes in the relevant tax jurisdiction. The number of employees may be reported as of the yearend, on the basis of average employment levels for the year or on any other basis consistently applied across tax jurisdictions and from year to year. For this purpose, independent contractors participating in the ordinary operating activities of the Constituent Entity may be reported as employees. Reasonable rounding or approximation of the number of employees is permissible, providing that such rounding or approximation does not materially distort the relative distribution of employees across the various tax jurisdictions. Consistent approaches should be applied from year to year and across entities. (i) Tangible Assets other than Cash and Cash Equivalents In the eleventh column of the template, the Reporting MNE should report the sum of the net book values of tangible assets of all the Constituent Entities resident for tax purposes in the relevant tax jurisdiction. With regard to permanent establishments, assets should be reported by reference to the tax jurisdiction in which the permanent establishment is situated. Tangible assets for this purpose do not include cash or cash equivalents, intangibles, or financial assets. 2. List of all the Constituent Entities of the MNE group included in each aggregation per tax jurisdiction (Table 2) (a) Constituent Entities Resident in the Tax Jurisdiction The Reporting MNE should list, on a tax jurisdiction-by-tax jurisdiction basis and by legal entity name, all the Constituent Entities of the MNE group which are resident for tax purposes in the relevant tax jurisdiction. As stated above with regard to permanent establishments, however, the permanent establishment should be listed by reference to the tax jurisdiction in which it is situated. The legal entity of which it is a permanent establishment should be noted (e.g. XYZ Corp - Tax Jurisdiction A PE). (b) Tax Jurisdiction of Organisation or Incorporation if Different from Tax Jurisdiction of Residence The Reporting MNE should report the name of the tax jurisdiction under whose laws the Constituent Entity of the MNE is organised or incorporated if it is different from the tax jurisdiction of residence. (c) Main Business Activity or Activities SCHEDULE Tax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017 SL 99 of 2017 The Reporting MNE should determine the nature of the main business activity or activities carried out by the Constituent Entity in the relevant tax jurisdiction, by ticking one or more of the appropriate boxes. Business Activities Research and Development Holding or Managing Intellectual Property Purchasing or Procurement Manufacturing or Production Sales, Marketing or Distribution Administrative, Management or Support Services Provision of Services to Unrelated Parties Internal Group Finance Regulated Financial Services Insurance Holding Shares or Other Equity Instruments Dormant Other 1 1. Please specify the nature of the activity of the Constituent Entity in the \u201cAdditional Information\u201d section. Made in Cabinet the 15th day of December, 2017. Davina Wilson Acting Clerk of the Cabinet.\", \"element\": \"section\", \"heading\": null}], \"meta\": {\"notes\": null, \"workflow\": null, \"lifecycle\": {\"source\": \"#cilegis\", \"eventRef\": [{\"eId\": \"e_commence_2017_01_01\", \"date\": \"2017-01-01\", \"type\": \"generation\", \"source\": \"#cilegis\"}]}, \"references\": {\"source\": \"#canary\", \"TLCRole\": [], \"TLCEvent\": [{\"eId\": \"ev_commencement\", \"href\": \"\/akn\/ontology\/canary\/event\/commencement\", \"showAs\": \"commencement\"}], \"TLCPerson\": [], \"TLCConcept\": [{\"eId\": \"inForce\", \"href\": \"\/akn\/ontology\/canary\/concept\/temporal\/in-force\", \"showAs\": \"in force\"}], \"TLCProcess\": [], \"TLCLocation\": [], \"TLCOrganization\": [{\"eId\": \"cilegis\", \"href\": \"\/akn\/ontology\/canary\/organization\/editor\/cilegis\", \"showAs\": \"Cayman Islands legislation mirror (kyleg)\"}]}, \"temporalData\": {\"source\": \"#cilegis\", \"temporalGroup\": [{\"eId\": \"tg_inforce_2017_01_01\", \"timeInterval\": [{\"end\": null, \"start\": \"#e_commence_2017_01_01\", \"duration\": null, \"refersTo\": \"#inForce\"}]}]}, \"classification\": null, \"identification\": {\"source\": \"#cilegis\", \"FRBRWork\": {\"FRBRuri\": \"\/akn\/ky\/act\/sl\/2017\/99\", \"FRBRdate\": [{\"date\": \"2017-01-01\", \"name\": \"generation\"}], \"FRBRthis\": \"\/akn\/ky\/act\/sl\/2017\/99\/!main\", \"FRBRalias\": [{\"name\": \"cmsId\", \"value\": \"2017-0099\"}], \"FRBRauthor\": [{\"as\": \"#editor\", \"href\": \"\/akn\/ontology\/canary\/organization\/editor\/cilegis\"}], \"FRBRnumber\": \"99 of 2017\", \"FRBRcountry\": \"ky\", \"FRBRsubtype\": \"subordinate\"}, \"FRBRExpression\": {\"FRBRuri\": \"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01\", \"FRBRdate\": [{\"date\": \"2017-01-01\", \"name\": \"generation\"}], \"FRBRthis\": \"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01\/!main\", \"FRBRauthor\": [{\"as\": \"#editor\", \"href\": \"\/akn\/ontology\/canary\/organization\/editor\/cilegis\"}], \"FRBRlanguage\": \"eng\"}, \"FRBRManifestation\": {\"FRBRuri\": \"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01.xml\", \"FRBRdate\": [{\"date\": \"2026-06-22\", \"name\": \"generation\"}], \"FRBRthis\": \"\/akn\/ky\/act\/sl\/2017\/99\/eng@2017-01-01.xml\", \"FRBRauthor\": [{\"as\": \"#editor\", \"href\": \"\/akn\/ontology\/canary\/organization\/editor\/cilegis\"}], \"FRBRformat\": \"application\/xml\"}}}, \"name\": \"act\", \"header\": {\"title\": \"Tax Information Authority (International Tax Compliance) (Country-By-Country Reporting) Regulations\", \"actNumber\": \"99 of 2017\", \"longTitle\": null}}, \"doc\": null, \"bill\": null, \"judgment\": null}}","akn_full_text":"CAYMAN ISLANDS\n\nTax Information Authority Law\nTAX INFORMATION AUTHORITY\n(INTERNATIONAL TAX COMPLIANCE)\n(COUNTRY-BY-COUNTRY REPORTING)\nREGULATIONS, 2017\n\n(SL 99 of 2017)\nSupplement No. 3 published with Extraordinary Gazette No. 106 dated 15th December, 2017.\n\nPage 2\nSL 99 of 2017\nc\n\nPUBLISHING DETAILS\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nArrangement of Regulations\n\nc\nSL 99 of 2017\nPage 3\n\nCAYMAN ISLANDS\n\nTax Information Authority Law\nTAX INFORMATION AUTHORITY\n(INTERNATIONAL TAX COMPLIANCE)\n(COUNTRY-BY-COUNTRY REPORTING)\nREGULATIONS, 2017\n(SL 99 of 2017)\nArrangement of Regulations\nRegulation\nPage\n1.\nCitation ......................................................................................................................................5\n2.\nDefinitions ..................................................................................................................................5\n3.\nEffective date .............................................................................................................................8\n4.\nFiling obligation ..........................................................................................................................8\n5.\nNotification obligation .................................................................................................................9\n6.\nCountry-by-Country Report ........................................................................................................9\n7.\nUse and Confidentiality of Country-by-Country Report Information ............................................9\n8.\nCompliance with notification and filing obligations .................................................................... 10\n9.\nGuidance ................................................................................................................................. 10\n10.\nCompliance measures ............................................................................................................. 11\n11.\nArrangement to avoid obligation .............................................................................................. 11\n12.\nOffence to contravene notification, reporting and monitoring regulations .................................. 11\n13.\nTampering ............................................................................................................................... 11\n14.\nHindering ................................................................................................................................. 12\n15.\nReasonable excuse defence .................................................................................................... 12\n16.\nPunishment on summary conviction ......................................................................................... 12\n17.\nAuthority\u2019s power to impose administrative penalty for offences ............................................... 12\n18.\nAdministrative penalty not to apply ........................................................................................... 12\n19.\nDaily default penalty ................................................................................................................ 13\n20.\nAdministrative penalties for inaccurate information .................................................................. 13\n\nArrangement of Regulations\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 4\nSL 99 of 2017\nc\n\n21.\nMatters to be disregarded in relation to liability to administrative penalties ............................... 13\n22.\nImposition of administrative penalties ...................................................................................... 14\n23.\nRight of appeal ........................................................................................................................ 14\nSCHEDULE\n15\nStandard template for Country-by-Country Report\n15\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nRegulation 1\n\nc\nSL 99 of 2017\nPage 5\n\nCAYMAN ISLANDS\n\nTax Information Authority Law\nTAX INFORMATION AUTHORITY\n(INTERNATIONAL TAX COMPLIANCE)\n(COUNTRY-BY-COUNTRY REPORTING)\nREGULATIONS, 2017\n(SL 99 of 2017)\nThe Cabinet, in exercise of the powers conferred by section 25 of the Tax Information\nAuthority Law (2017 Revision), makes the following Regulations \u2014\n1.\nCitation\n1.\nThese Regulations may be cited as the Tax Information Authority (International Tax\nCompliance) (Country-By-Country Reporting) Regulations, 2017.\n2.\nDefinitions\n2.\n(1) In these Regulations \u2014\n\u201cAuthority\u201d means the Tax Information Authority designated under section 4\nof the Law, or a person designated by the Authority to act on behalf of the\nAuthority;\n\u201cConsolidated Financial Statements\u201d means the financial statements of an\nMNE Group in which the assets, liabilities, income, expenses and cash flows\nof the Ultimate Parent Entity and the Constituent Entities are presented as\nthose of a single economic entity;\n\u201cConstituent Entity\u201d means \u2014\n\nRegulation 2\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 6\nSL 99 of 2017\nc\n\n(a)\nany separate business unit of an MNE Group that is included in the\nConsolidated Financial Statements of the MNE Group for financial\nreporting purposes, or would be so included if equity interests in such\nbusiness unit of an MNE Group were traded on a public securities\nexchange;\n(b) any such business unit that is excluded from the MNE Group\u2019s\nConsolidated Financial Statements solely on size or materiality\ngrounds; and\n(c)\nany permanent establishment of any separate business unit of the MNE\nGroup included in (a) or (b) provided the business unit prepares a\nseparate financial statement for such permanent establishment for\nfinancial reporting, regulatory, tax reporting, or internal management\ncontrol purposes;\n\u201cExcluded MNE Group\u201d means, with respect to any Fiscal Year of the\nGroup, a Group having total consolidated group revenue of less than eight\nhundred and fifty million United States Dollars during the Fiscal Year\nimmediately preceding the Reporting Fiscal Year as reflected in its\nConsolidated Financial Statements for such preceding Fiscal Year;\n\u201cFiscal Year\u201d means an annual accounting period with respect to which the\nUltimate Parent Entity of the MNE Group prepares its financial statements;\n\u201cGroup\u201d means a collection of enterprises related through ownership or\ncontrol such that it is either required to prepare Consolidated Financial\nStatements for financial reporting purposes under applicable accounting\nprinciples or would be so required if equity interests in any of the enterprises\nwere traded on a public securities exchange;\n\u201cInternational Agreement\u201d means the Multilateral Convention for Mutual\nAdministrative Assistance in Tax Matters, any bilateral or multilateral Tax\nConvention or any Tax Information Exchange Agreement to which the\nCayman Islands is a party and that, by its terms, provides legal authority for\nthe exchange of tax information between jurisdictions including the automatic\nexchange of such information;\n\u201cMNE Group\u201d means any Group that \u2014\n(a)\nincludes two or more enterprises for which the tax residence is in\ndifferent jurisdictions or includes an enterprise that is resident for tax\npurposes in one jurisdiction and is subject to tax with respect to the\nbusiness carried out through a permanent establishment in another\njurisdiction; and\n(b) is not an Excluded MNE Group;\n\u201cOECD Final Report\u201d means the document entitled \u201cTransfer Pricing\nDocumentation and Country-by-Country Reporting, Action 13 - 2015 Final\nReport\u201d published by the Organization for Economic Co-operation and\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nRegulation 2\n\nc\nSL 99 of 2017\nPage 7\n\nDevelopment as part of the OECD\/G20 Base Erosion and Profit Shifting\nProject as may be amended from time to time;\n\u201cQualifying Competent Authority Agreement\u201d means an agreement that \u2014\n(a)\nis between authorised representatives of those jurisdictions that are\nparties to an International Agreement; and\n(b) requires the automatic exchange of Country-by-Country Reports between\nthe party jurisdictions;\n\u201cReporting Entity\u201d means the Constituent Entity which is required to file a\nCountry-by-Country Report conforming to the requirements in regulation 6 in\nits jurisdiction of tax residence on behalf of the MNE Group and which may\nbe the Ultimate Parent Entity or the Surrogate Parent Entity;\n\u201cReporting Fiscal Year\u201d means the Fiscal Year to which the operational\nresults in the Country-by-Country Report (described in regulation 6) relate;\n\u201cresident in the Islands\u201d for a Constituent Entity means \u2014\n(a)\nbeing incorporated or established in the Islands;\n(b) having a place of effective management in the Islands; or\n(c)\nbeing subject to financial supervision in the Islands;\n\u201cSurrogate Parent Entity\u201d means one Constituent Entity of the MNE Group\nthat has been appointed by the MNE Group as a sole substitute for the\nUltimate Parent Entity to file the Country-by-Country Report in that\nConstituent Entity\u2019s jurisdiction of tax residence on behalf of the said MNE\nGroup when one or more of the conditions set out in regulation 4(2)(b)\napplies;\n\u201cSystemic Failure\u201d with respect to a jurisdiction means that the jurisdiction\nhas a Qualifying Competent Authority Agreement in effect with the Cayman\nIslands, but has suspended automatic exchange (for reasons other than those\nthat are in accordance with the terms of that Agreement) or otherwise\npersistently failed to automatically provide to the Cayman Islands Country-by\nCountry Reports in its possession of MNE Groups that have Constituent\nEntities in the Cayman Islands; and\n\u201cUltimate Parent Entity\u201d means a Constituent Entity of an MNE Group that\nmeets the following criteria \u2014\n(a)\nit owns directly or indirectly a sufficient interest in one or more other\nConstituent Entities of the MNE Group such that it is required to prepare\nConsolidated Financial Statements under accounting principles generally\napplied in its jurisdiction of tax residence, or would be so required if its\nequity interests were traded on public securities exchange in its\njurisdiction of tax residence; and\n\nRegulation 3\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 8\nSL 99 of 2017\nc\n\n(b) there is no other Constituent Entity of the MNE Group that owns directly\nor indirectly an interest described in paragraph (a) in the first mentioned\nConstituent Entity.\n(2) For the purposes of these Regulations, unless the context otherwise requires,\nthe words \u201cjurisdiction of tax residence\u201d, \u201ctax residence\u201d and \u201cresident for tax\npurposes\u201d shall each be considered as incorporating a reference to \u201cresident in\nthe Islands\u201d.\n(3) In these Regulations, a word or expression used in these Regulations and\ndefined in the OECD Final Report but not in these Regulations has the\nmeaning assigned to it in the OECD Final Report.\n3.\nEffective date\n3.\nThese Regulations shall enter into force in the Islands on the date of publication and\nare effective for Reporting Fiscal Years of MNE Groups beginning on or after 1\nJanuary 2016.\n4.\nFiling obligation\n4.\n(1) Each Ultimate Parent Entity of an MNE Group that is resident in the Islands\nshall file with the Authority a Country-by-Country Report conforming to the\nrequirements of regulation 6 with respect to its Reporting Fiscal Year on or\nbefore the date specified in regulation 6(3).\n(2) A Surrogate Parent Entity shall file with the Authority on or before the date\nspecified in regulation 6(3) a Country-By-Country Report conforming to the\nrequirements of these Regulations with respect to the Reporting Fiscal Year of\nan MNE Group of which it is a Surrogate Parent Entity if \u2014\n(a)\nthe entity is resident in the Islands; and\n(b) one of the following conditions applies \u2014\n(i)\nthe Ultimate Parent Entity of the MNE Group is not obligated to file\na Country-By-Country Report in its jurisdiction of tax residence;\n(ii) the jurisdiction in which the Ultimate Parent Entity is resident for\ntax purposes has a current International Agreement to which the\nCayman Islands is a party but does not have a Qualifying\nCompetent Authority Agreement in effect to which the Cayman\nIslands is a party by the time specified in regulation 6(3) for filing\nthe Report for the Reporting Fiscal Year; or\n(iii) there has been a Systemic Failure of the jurisdiction of tax residence\nof the Ultimate Parent Entity that has been notified by the Authority\nto the Constituent Entity resident in the Islands.\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nRegulation 5\n\nc\nSL 99 of 2017\nPage 9\n\n5.\nNotification obligation\n5.\n(1) Any Constituent Entity that is resident in the Islands shall notify the Authority\nof whether it is the Ultimate Parent Entity or the Surrogate Parent Entity no\nlater than the last day of the Reporting Fiscal Year of the MNE Group except\nthat such notification shall be filed by 31 March, 2018 with respect to the\nReporting Fiscal Year of the MNE Group that began during 2016.\n(2) Where a Constituent Entity that is resident in the Islands is not the Ultimate\nParent Entity nor the Surrogate Parent Entity, it shall notify the Authority of\nthe identity and tax residence of the Reporting Entity no later than the last day\nof the Reporting Fiscal Year of such MNE Group except that notification\nunder paragraph (1) shall be filed by 31 March, 2018 with respect to the\nReporting Fiscal Year of the MNE Group that began during 2016.\n6.\nCountry-by-Country Report\n6.\n(1) For the purposes of these Regulations, a Country-by-Country Report with\nrespect to an MNE Group is a report containing \u2014\n(a)\naggregate information relating to the amount of revenue, profit (or loss)\nbefore income tax, income tax paid, income tax accrued, stated capital,\naccumulated earnings, number of employees and tangible assets other\nthan cash or cash equivalents with regard to each jurisdiction in which\nthe MNE Group operates; and\n(b) an identification of each Constituent Entity of the MNE Group setting\nout the jurisdiction of tax residence of such Constituent Entity and, where\ndifferent from such jurisdiction of tax residence, the jurisdiction under\nthe laws of which such Constituent Entity is organized and the nature of\nthe main business activity or activities of such Constituent Entity.\n(2) The Country-by-Country Report shall be filed in a form identical to the\nstandard template set out in Tables 1, 2 and 3 in Part 1 of the Schedule to these\nRegulations and the instructions contained in Part 2 of the Schedule shall\napply.\n(3) The Country-by-Country Report required by these Regulations shall be filed\nno later than twelve months after the last day of the Reporting Fiscal Year of\nthe MNE Group except that the Country-by-Country Report required\nwith respect to the Reporting Fiscal Year that began on or before 31 March\n2016 shall be filed no later than 31 March 2018.\n7.\nUse and Confidentiality of Country-by-Country Report Information\n7.\n(1) The Authority shall use the Country-by-Country Report and any other\ninformation obtained pursuant to these Regulations for purposes of\ncollaboration on compliance and enforcement with other Competent\nAuthorities pursuant to a Qualifying Competent Authority Agreement.\n\nRegulation 8\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 10\nSL 99 of 2017\nc\n\n(2) The Authority shall preserve the confidentiality of the information contained\nin the Country-by-Country Report at least to the same extent that would apply\nif such information were provided to it under the provisions of the Multilateral\nConvention on Mutual Administrative Assistance in Tax Matters.\n8.\nCompliance with notification and filing obligations\n8.\n(1) A Constituent Entity shall comply with notification and filing obligations in\nthe form and manner specified through use of the electronic portal or such\nother method as may be prescribed by the Authority.\n(2) The Authority shall notify Constituent Entities of the method of compliance\nwith the notification and filing obligations by \u2014\n(a)\na post on an official website providing information generally; or\n(b) a notice given to a particular Constituent Entity.\n(3) Unless the contrary is proved, the Authority shall assume that a return that has\nbeen accepted by the electronic portal or such other method of compliance as\nmay be prescribed \u2014\n(a)\nhas been made as required under paragraph (1); and\n(b) was made \u2014\n(i)\nwhen the return was accepted by the portal or such other method of\ncompliance as may be prescribed;\n(ii) by the person who made the return by using the portal; and\n(iii) with the authority of the Constituent Entity on whose behalf the\nreturn purports to have been made.\n(4) For the purposes of this regulation \u2014\n\u201celectronic address\u201d includes an email address and the address of a digital\nmailbox;\n\u201celectronic portal\u201d means the Authority\u2019s electronic portal for the automatic\nexchange of information; and\n\u201cofficial website\u201d means \u2014\n(a)\nthe website of the Department for International Tax Cooperation;\n(b) a website of the Authority; or\n(c)\nany another Government website about international tax cooperation.\n9.\nGuidance\n9.\nThe Authority may issue guidance for complying with these Regulations.\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nRegulation 10\n\nc\nSL 99 of 2017\nPage 11\n\n10.\nCompliance measures\n10. (1) The Authority may, by notice given to a Constituent Entity, require the\nConstituent Entity \u2014\n(a)\nto provide to the Authority, within a time specified by the Authority, any\ninformation, such information including a copy of a relevant book,\ndocument, electronically stored information or other record as may be in\nthe Constituent Entity\u2019s possession or under its control that the Authority\nreasonably requires to determine the accuracy of information that the\nConstituent Entity gave to the Authority ; or\n(b) to make available to the Authority for inspection, at a time specified by\nthe Authority, any book, document, electronically stored information or\nother record that is in the Constituent Entity\u2019s possession or under its\ncontrol that the Authority reasonably requires to determine the accuracy\nof information provided by the Constituent Entity to the Authority.\n(2) If information the Authority requires for inspection or otherwise is outside of\nthe Islands and the Authority requires the Constituent Entity to bring the\ninformation to the Islands, the Authority shall specify a time period that will\nenable the Constituent Entity to bring the information to the Islands and the\nConstituent Entity shall comply with the requirement of the Authority.\n(3) A Constituent Entity shall retain for six years any book, document,\nelectronically-stored information or other record that relates to the information\nrequired to be reported to the Authority under these Regulations.\n11.\nArrangement to avoid obligation\n11. If a person enters into an arrangement, a main purpose of which is to avoid an\nobligation under these Regulations, the arrangement, for the purposes of these\nRegulations, shall be deemed to be one which was not entered into and these\nRegulations shall have effect as if the arrangement had never been in existence.\n12.\nOffence to contravene notification, reporting and monitoring regulations\n12. A person commits an offence if that person contravenes regulations 4, 5, 6, 8 or 10.\n13.\nTampering\n13. A person commits an offence if the person \u2014\n(a)\nalters, destroys, mutilates, defaces, hides or removes information in a\nway that causes the person or anyone else to contravene these\nRegulations in relation to the information; or\n(b) authorizes, advises or counsels someone else to do anything referred to in\nparagraph (a).\n\nRegulation 14\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 12\nSL 99 of 2017\nc\n\n14.\nHindering\n14. A person commits an offence if the person hinders the Authority in performing a\nfunction under these Regulations.\n15.\nReasonable excuse defence\n15. (1) In proceedings against a person for an offence under these Regulations, it is a\ndefence to prove that the person had a reasonable excuse.\n(2) Neither insufficiency of funds nor reliance on an agent or reliance on any other\nperson is a reasonable excuse.\n(3) If a defendant had a reasonable excuse for committing an offence but the\nexcuse ceases to exist, the defendant shall be considered as still having the\nreasonable excuse if the offence was remedied without undue delay after the\nexcuse ceased to exist.\n16.\nPunishment on summary conviction\n16. Subject to regulation 17, a person who commits an offence under these Regulations\nis liable on summary conviction to a fine of ten thousand dollars or to imprisonment\nfor a term of six months, or to both.\n17.\nAuthority\u2019s power to impose administrative penalty for offences\n17. (1) The Authority may impose an administrative penalty of four thousand dollars\nwhere a person contravenes regulation 12, 13 or 14.\n(2) An administrative penalty imposed under this regulation shall be in accordance\nwith the provisions in regulations 18 and 22.\n(3) Where the Authority decides to impose an administrative penalty it shall notify\nthe person of its decision.\n(4) A notice under these Regulations may be in such form as the Authority\ndetermines and shall include the person\u2019s name, the reasons for imposing the\npenalty, the amount of the penalty and when it becomes due.\n18.\nAdministrative penalty not to apply\n18. (1) Where a person is convicted in a court of law of an offence under these\nRegulations, that person shall not also be liable to an administrative penalty\nunder these Regulations in relation to the same facts.\n(2) Where an administrative penalty is imposed under these Regulations, the\nperson liable for that penalty shall not be subsequently or simultaneously\ncharged with an offence under these Regulations in relation to the same facts.\n(3) Any administrative penalty payable under these Regulations may be recovered\nby the Crown in a court as a civil debt.\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nRegulation 19\n\nc\nSL 99 of 2017\nPage 13\n\n19.\nDaily default penalty\n19. (1) A person who fails to pay the administrative penalty imposed under regulation\n17 shall be liable to an additional penalty of an amount of two hundred dollars\nfor each day during which the penalty imposed under regulation 17 remains\nunpaid.\n(2) Where the Authority decides to impose a daily default penalty it may only do\nso where it notifies the person who has failed to pay the administrative penalty\nof its decision.\n(3) A notice under these Regulations may be in such form as the Authority\ndetermines including the person\u2019s name, the reasons for imposing the penalty,\nthe amount of the penalty and when it becomes or became due.\n20.\nAdministrative penalties for inaccurate information\n20. (1) A person is liable to an administrative penalty of five thousand dollars, if \u2014\n(a)\nthe person provides inaccurate information when filing a Country-ByCountry Report; and\n(b) satisfies condition A or B in paragraphs (2) and (3).\n(2) Condition A is that the person knows of the inaccuracy at the time that the\ninformation is provided in the Report but does not inform the Authority of the\ninaccuracy at that time.\n(3) Condition B is that the person \u2014\n(a)\ndiscovers the inaccuracy after the information is provided in the Report\nto the Authority; and\n(b) fails to take reasonable steps to inform the Authority of the inaccuracy.\n21.\nMatters to be disregarded in relation to liability to administrative penalties\n21. (1) Liability to an administrative penalty under these Regulations does not arise if\nthere is a reasonable excuse for the failure to comply with the relevant\nprovisions or for the provision of inaccurate information.\n(2) For the purposes of this regulation, neither of the following is a reasonable\nexcuse \u2014\n(a)\nthat there is an insufficiency of funds to do something; or\n(b) that a person relies upon another person to do something.\n(3) If a person had a reasonable excuse for a failure to comply but the excuse has\nceased to exist, the person is to be treated as having continued to have the\nexcuse if the failure is remedied without undue delay after the excuse had\nceased to exist.\n\nRegulation 22\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 14\nSL 99 of 2017\nc\n\n22.\nImposition of administrative penalties\n22. (1) If a person becomes liable to an administrative penalty under these\nRegulations, the Authority may impose the penalty in accordance with this\nregulation.\n(2) If the Authority intends to impose an administrative penalty, the Authority\nmust notify the person of its intention and the notice must specify \u2014\n(a)\nthe Authority\u2019s reasons for holding the person liable to an administrative\npenalty; and\n(b) a reasonable period (which may not be less than fourteen days) within\nwhich the person to whom the notice is given may make representations\nto the Authority, and where such representations are made, the Authority\nshall take them into account in deciding whether to impose the\nadministrative penalty.\n(3) An administrative penalty under regulation 17 or 19 may only be imposed\nwithin the period of twelve months beginning with the date on which the\nperson became liable to the penalty.\n(4) An administrative penalty under regulation 20 may only be imposed \u2014\n(a)\nwithin the period of twelve months beginning with the date on which the\ninaccuracy first came to the attention of the Authority; and\n(b) within the period of six years beginning with the date on which the\nperson became liable to the penalty.\n(5) The Authority shall provide written reasons to the person on whom a penalty\nis imposed for any decision to impose an administrative penalty within a\nreasonable period of time of the decision.\n23.\nRight of appeal\n23. (1) A person upon whom an administrative penalty is imposed may, subject to this\nregulation, appeal against it to the Grand Court and such appeal shall act as a\nstay on the enforcement of the administrative penalty.\n(2) An appeal under this regulation may be made on questions of law or fact or\nboth and the Grand Court may affirm or reverse the penalty or substitute its\nown penalty for that imposed by the Authority.\n(3) A person upon whom an administrative penalty is imposed may appeal it on\nthe ground that liability to a penalty does not arise.\n(4) A person upon whom an administrative penalty is imposed may appeal against\nthe amount imposed by the Authority.\n(5) For the avoidance of doubt, this regulation does not limit or otherwise affect\nany obligation of the person or Constituent Entity under these Regulations.\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nSCHEDULE\n\nc\nSL 99 of 2017\nPage 15\n\n SCHEDULE\n(Regulation 6)\nStandard template for Country-by-Country Report\nPart 1\n\nTable 1. Overview of allocation of income, taxes and business activities by tax jurisdiction\nName of\nthe MNE\nGroup:\nFiscal year\nconcerned:\nCurrency\nused:\nTax\nJurisdiction\nRevenues\nProfit\n(Loss)\nbefore\nIncome\nTax\nIncome\nTax\nPaid\n(on\nCash\nBasis)\nIncome\nTax\nAccrued\n-\nCurrent\nYear\nStated\nCapital\nAccumulated\nEarnings\nNumber of\nEmployees\nTangible\nAssets\nother than\nCash and\nCash\nEquivalents\nUnrelated\nParty\nRelated\nParty\nTotal\n\nSCHEDULE\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 16\nSL 99 of 2017\nc\n\n1\nPlease specify the nature of the activity of the Constituent Entity in the \u201cAdditional\nInformation\u201d section.\n\nTax Jurisdiction\nTable 2. List of all the Constituent Entities of the MNE Group included in each\naggregation per tax jurisdiction\n3\n2\n1\n3\n2\n1\nConstituent Entities Resident in the Tax\nJurisdiction\nTax Jurisdiction of Organisation or Incorporation if\nDifferent from Tax Jurisdiction of Residence\nResearch and Development\nMain Business Activity or Activities\nHolding or Managing  Intellectual Property\nPurchasing or Procurement\nManufacturing or Production\nSales, Marketing or Distribution\nAdministrative, Management  or Support Services\nProvision of Services to  Unrelated Parties\nInternal Group Finance\nRegulated Financial  Services\nInsurance\nHolding Shares or Other  Equity instruments\nDormant\nOther1\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nSCHEDULE\n\nc\nSL 99 of 2017\nPage 17\n\nTable 3. Additional Information\nName of the MNE Group:\n\nFiscal year concerned:\n\nPlease include any further brief\ninformation or explanation you\nconsider necessary or that would\nfacilitate the understanding of the\ncompulsory information provided\nin the Country-by-Country Report.\n\nPart 2 - General and Specific Instructions for Standard Template Country-byCountry Report\nA.\nGeneral instructions\n1.\nPurpose\nTable 1 to this Schedule contains a template for reporting a multinational enterprise\u2019s\n(MNE) group allocation of income, taxes and business activities on a tax jurisdiction-bytax jurisdiction basis. These instructions form an integral part of the model template for\nthe Country-by-Country Report.\n2.\nDefinitions\n(a)\nReporting MNE\nA Reporting MNE is the ultimate parent entity of an MNE group.\n(b) Constituent Entity\nFor purposes of completing the Country-by-Country Report, a Constituent\nEntity of the MNE group is -\n(i)\nany separate business unit of an MNE group that is included in the\nConsolidated Financial Statements of the MNE group for financial\nreporting purposes, or would be so included if equity interests in\nsuch business unit of the MNE group were traded on a public\nsecurities exchange;\n(ii) any such business unit that is excluded from the MNE group\u2019s\nConsolidated Financial Statements solely on size or materiality\ngrounds; and\n\nSCHEDULE\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 18\nSL 99 of 2017\nc\n\n(iii) any permanent establishment of any separate business unit of the\nMNE group included in subparagraphs (i) or (ii) provided the\nbusiness unit prepares a separate financial statement for such\npermanent establishment for financial reporting, regulatory, tax\nreporting, or internal management control purposes.\n(c)\nTreatment of Branches and Permanent Establishments\nThe permanent establishment data should be reported by reference to the\ntax jurisdiction in which it is situated and not by reference to the tax\njurisdiction of residence of the business unit of which the permanent\nestablishment is a part. Residence tax jurisdiction reporting for the\nbusiness unit of which the permanent establishment is a part should\nexclude financial data related to the permanent establishment.\n(d) Consolidated Financial Statements\nThe Consolidated Financial Statements are the financial statements of an\nMNE group in which the assets, liabilities, income, expenses and cash\nflows of the ultimate parent entity and the Constituent Entities are\npresented as those of a single economic entity.\n3.\nPeriod covered by the annual template\nThe template should cover the fiscal year of the Reporting MNE. For Constituent\nEntities, at the discretion of the Reporting MNE, the template should reflect on a\nconsistent basis either -\n(i)\ninformation for the fiscal year of the relevant Constituent Entities\nending on the same date as the fiscal year of the Reporting MNE, or\nending within the 12 month period preceding such date; or\n(ii) information for all the relevant Constituent Entities reported for the\nfiscal year of the Reporting MNE.\n4.\nSource of data\nThe Reporting MNE should consistently use the same sources of data from year to year\nin completing the template. The Reporting MNE may choose to use data from its\nconsolidation reporting packages, from separate entity statutory financial statements,\nregulatory financial statements, or internal management accounts. It is not necessary to\nreconcile the revenue, profit and tax reporting in the template to the Consolidated\nFinancial Statements. If statutory financial statements are used as the basis for reporting,\nall amounts should be translated to the stated functional currency of the Reporting MNE\nat the average exchange rate for the year stated in the \u201cAdditional Information\u201d section of\nthe template.\nAdjustments need not be made, however, for differences in accounting principles applied\nfrom tax jurisdiction to tax jurisdiction.\nThe Reporting MNE should provide a brief description of the sources of data used in\npreparing the template in the \u201cAdditional Information\u201d section of the template. If a\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nSCHEDULE\n\nc\nSL 99 of 2017\nPage 19\n\nchange is made in the source of data used from year to year, the Reporting MNE should\nexplain the reasons for the change and its consequences in the \u201cAdditional Information\u201d\nsection of the template.\nB.\nSpecific instructions for standard template Country-by-Country Report\n1.\nOverview of allocation of income, taxes and business activities by tax\njurisdiction (Table 1)\n(a)\nTax Jurisdiction\nIn the first column of the template, the Reporting MNE should list all of\nthe tax jurisdictions in which Constituent Entities of the MNE group are\nresident for tax purposes.\nA tax jurisdiction is defined as a State as well as a non-State jurisdiction\nwhich has fiscal autonomy. A separate line should be included for all\nConstituent Entities in the MNE group deemed by the Reporting MNE\nnot to be resident in any tax jurisdiction for tax purposes.\nWhere a Constituent Entity is resident in more than one tax jurisdiction,\nthe applicable tax treaty \u201ctie breaker\u201d should be applied to determine the\ntax jurisdiction of residence.\nWhere no applicable tax treaty exists, the Constituent Entity should be\nreported in the tax jurisdiction of the Constituent Entity\u2019s place of\neffective management. The place of effective management should be\ndetermined in accordance with the provisions of Article 4 of the OECD\nModel Tax Convention and its accompanying Commentary.\n(b) Revenues\nIn the three columns of the template under the heading Revenues, the\nReporting MNE should report the following information -\n(i)\nthe sum of revenues of all the Constituent Entities of the MNE\ngroup in the relevant tax jurisdiction generated from transactions\nwith associated enterprises;\n(ii) the sum of revenues of all the Constituent Entities of the MNE\ngroup in the relevant tax jurisdiction generated from transactions\nwith independent parties; and\n(iii) the total of (i) and (ii).\nRevenues should include revenues from sales of inventory and\nproperties, services, royalties, interest, premiums and any other amounts.\nRevenues should exclude payments received from other Constituent\nEntities that are treated as dividends in the payor\u2019s tax jurisdiction.\n(c)\nProfit (Loss) before Income Tax\nIn the fifth column of the template, the Reporting MNE should report the\nsum of the profit (loss) before income tax for all of the Constituent\n\nSCHEDULE\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 20\nSL 99 of 2017\nc\n\nEntities resident for tax purposes in the relevant tax jurisdiction. The\nprofit (loss) before income tax should include all extraordinary income\nand expense items.\n(d) Income Tax Paid (on Cash Basis)\nIn the sixth column of the template, the Reporting MNE should report the\ntotal amount of income tax actually paid during the relevant fiscal year\nby all the Constituent Entities resident for tax purposes in the relevant tax\njurisdiction. Taxes paid should include cash taxes paid by the Constituent\nEntity to the residence tax jurisdiction and to all other tax jurisdictions.\nTaxes paid should include withholding taxes paid by other entities\n(associated enterprises and independent enterprises) with respect to\npayments to the Constituent Entity.\nThus, if company A resident in tax jurisdiction A earns interest in tax\njurisdiction B, the tax withheld in tax jurisdiction B should be reported\nby company A.\n(e)\nIncome Tax Accrued (Current Year)\nIn the seventh column of the template, the Reporting MNE should report\nthe sum of the accrued current tax expense recorded on taxable profits or\nlosses of the year of reporting of all the Constituent Entities resident for\ntax purposes in the relevant tax jurisdiction.\nThe current tax expense should reflect only operations in the current year\nand should not include deferred taxes or provisions for uncertain tax\nliabilities.\n(f)\nStated Capital\nIn the eighth column of the template, the Reporting MNE should report\nthe sum of the stated capital of all the Constituent Entities resident for tax\npurposes in the relevant tax jurisdiction. With regard to permanent\nestablishments, the stated capital should be reported by the legal entity of\nwhich it is a permanent establishment unless there is a defined capital\nrequirement in the permanent establishment tax jurisdiction for\nregulatory purposes.\n(g) Accumulated Earnings\nIn the ninth column of the template, the Reporting MNE should report\nthe sum of the total accumulated earnings of all the Constituent Entities\nresident for tax purposes in the relevant tax jurisdiction as of the end of\nthe year. With regard to permanent establishments, accumulated earnings\nshould be reported by the legal entity of which it is a permanent\nestablishment.\n(h) Number of Employees\n\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\nSCHEDULE\n\nc\nSL 99 of 2017\nPage 21\n\nIn the tenth column of the template, the Reporting MNE should report\nthe total number of employees on a full-time equivalent (FTE) basis of\nall the Constituent Entities resident for tax purposes in the relevant tax\njurisdiction. The number of employees may be reported as of the yearend, on the basis of average employment levels for the year or on any\nother basis consistently applied across tax jurisdictions and from year to\nyear. For this purpose, independent contractors participating in the\nordinary operating activities of the Constituent Entity may be reported as\nemployees. Reasonable rounding or approximation of the number of\nemployees is permissible, providing that such rounding or approximation\ndoes not materially distort the relative distribution of employees across\nthe various tax jurisdictions.\nConsistent approaches should be applied from year to year and across\nentities.\n(i)\nTangible Assets other than Cash and Cash Equivalents\nIn the eleventh column of the template, the Reporting MNE should report\nthe sum of the net book values of tangible assets of all the Constituent\nEntities resident for tax purposes in the relevant tax jurisdiction. With\nregard to permanent establishments, assets should be reported by\nreference to the tax jurisdiction in which the permanent establishment is\nsituated. Tangible assets for this purpose do not include cash or cash\nequivalents, intangibles, or financial assets.\n2.\nList of all the Constituent Entities of the MNE group included in each\naggregation per tax jurisdiction (Table 2)\n(a)\nConstituent Entities Resident in the Tax Jurisdiction\nThe Reporting MNE should list, on a tax jurisdiction-by-tax jurisdiction\nbasis and by legal entity name, all the Constituent Entities of the MNE\ngroup which are resident for tax purposes in the relevant tax jurisdiction.\nAs stated above with regard to permanent establishments, however, the\npermanent establishment should be listed by reference to the tax\njurisdiction in which it is situated. The legal entity of which it is a\npermanent establishment should be noted (e.g. XYZ Corp - Tax\nJurisdiction A PE).\n(b) Tax Jurisdiction of Organisation or Incorporation if Different from Tax\nJurisdiction of Residence\nThe Reporting MNE should report the name of the tax jurisdiction under\nwhose laws the Constituent Entity of the MNE is organised or\nincorporated if it is different from the tax jurisdiction of residence.\n(c)\nMain Business Activity or Activities\n\nSCHEDULE\nTax Information Authority (International Tax Compliance) (Country-ByCountry Reporting) Regulations, 2017\n\nPage 22\nSL 99 of 2017\nc\n\nThe Reporting MNE should determine the nature of the main business\nactivity or activities carried out by the Constituent Entity in the relevant\ntax jurisdiction, by ticking one or more of the appropriate boxes.\n\nBusiness Activities\nResearch and Development\nHolding or Managing Intellectual Property\nPurchasing or Procurement\nManufacturing or Production\nSales, Marketing or Distribution\nAdministrative, Management or Support Services\nProvision of Services to Unrelated Parties\nInternal Group Finance\nRegulated Financial Services\nInsurance\nHolding Shares or Other Equity Instruments\nDormant\nOther 1\n1.\nPlease specify the nature of the activity of the Constituent Entity in the \u201cAdditional\nInformation\u201d section.\nMade in Cabinet the 15th day of December, 2017.\nDavina Wilson Acting\nClerk of the Cabinet.","akn_extracted_at":"2026-06-22 15:40:46.956657+00","cms_id":"2017-0099","law_type":"subordinate","year":"2017","number":"99","title":"Tax Information Authority (International Tax Compliance) (Country-By-Country Reporting) Regulations","status":"in_force"},"provenance":{"files":[{"file_id":"5418","expr_id":"451","kind":"akn_xml","filename":"2017-0099_SL 99 of 2017.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2017\/2017-0099\/2017-0099_SL 99 of 2017.akn.xml","content_md5":"837f0c5e481456e91fe263d29ef73726","byte_size":"43465","http_last_modified":null,"fetched_at":"2026-06-22 15:40:47.120103+00"},{"file_id":"901","expr_id":"451","kind":"pristine_pdf","filename":"2017-0099_SL 99 of 2017.pdf","source_url":"\/cms\/images\/LEGISLATION\/SUBORDINATE\/2017\/2017-0099\/2017-0099_SL 99 of 2017.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/SUBORDINATE\/2017\/2017-0099\/2017-0099_SL 99 of 2017.pdf","content_md5":"f94491b303ea96101385de7599093a88","byte_size":"630264","http_last_modified":null,"fetched_at":"2026-06-21 23:09:38.214526+00"},{"file_id":"902","expr_id":"451","kind":"working_pdf","filename":"2017-0099_SL 99 of 2017.pdf","source_url":"\/cms\/images\/LEGISLATION\/SUBORDINATE\/2017\/2017-0099\/2017-0099_SL 99 of 2017.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/SUBORDINATE\/2017\/2017-0099\/2017-0099_SL 99 of 2017.pdf","content_md5":"f94491b303ea96101385de7599093a88","byte_size":"630264","http_last_modified":null,"fetched_at":"2026-06-21 23:09:38.214526+00"}],"paragraph_count":15,"latest_history":null},"quality":{"expr_id":"451","doc_id":"451","quality_state":"needs_review","quality_score":"84","needs_human_review":"t","deterministic_categories":"{duplicate_text,page_header_footer_noise}","llm_categories":"{other}","repair_actions":"{collapse_duplicate_text,manual_review,strip_page_furniture}","finding_severity_counts":"{\"medium\": 1}","finding_summary":"Sample ends with partial schedule content and an omission marker; duplicate title blocks warrant review but do not preclude further processing.","assessed_at":"2026-06-22 15:29:46.159112+00","updated_at":"2026-06-22 15:29:46.159112+00"}}