Country-by-Country Reporting

The Country-by-Country (CbC) report is a form that multinational enterprise groups (MNE group) are required to complete and file annually to provide information of their global operations in each tax jurisdiction where they do business. The Country-by-Country Reporting Regulation sets forth the rules governing the submission of CbC Reports to MIRA by multinational enterprises resident in the Maldives.

Ultimate Parent Entity of an MNE group with more than €750 million in consolidated group revenue in the immediately preceding fiscal year have to file a CbC Report. The CbC Report is required to be filed with MIRA no later than 12 months after the last day of the Reporting Fiscal Year of the MNE Group.

An MNE group can appoint a Constituent Entity as a Surrogate Parent Entity, as a sole substitute for the Ultimate Parent Entity, to file the CbC Report in that Constituent Entity’s jurisdiction of tax residence, on behalf of such MNE Group, when one or more of the conditions set out in the below paragraph applies.

A Constituent Entity which is not the Ultimate Parent Entity of an MNE Group shall file a CBC Report with MIRA with respect to the Reporting Fiscal Year of an MNE Group of which it is a Constituent Entity, if the following criteria are satisfied:

1. 1. the entity is resident in the Maldives for tax purposes; and
   2. one of the following conditions applies:

(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; or,

(ii) the jurisdiction in which the Ultimate Parent Entity is resident for tax purposes has a current International Agreement to which the Maldives is a party but does not have a Qualifying Competent Authority Agreement in effect to which the Maldives is a party to; or,

(iii) there has been a Systemic Failure of the jurisdiction of tax residence of the Ultimate Parent Entity that has been notified by MIRA to the Constituent Entity resident for tax purposes in the Maldives.

Where there is more than one constituent entity of the same MNE group that would be required to file a CbC report, one may be designated, and this must be notified to MIRA by emailing at [email protected].

Any Constituent Entity of an MNE Group that is resident for tax purposes in the Maldives shall notify MIRA whether it is the Ultimate Parent Entity or the Surrogate Parent Entity, no later than the last day of the Reporting Fiscal Year of such MNE Group. Where a Constituent Entity of an MNE Group that is resident for tax purposes in the Maldives is not the Ultimate Parent Entity nor the Surrogate Parent Entity, it shall notify MIRA 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. This notification is required for every year.

To notify MIRA, all constituent entities of MNE groups required to submit the CbC report should email the following details to [email protected] .

1. 1.  Full legal name of the constituent entity in Maldives
   2. TIN of the constituent entity in Maldives
   3.  Full address of the constituent entity in Maldives
   4.  Contact person from constituent entity for CbCR purposes

Classification of constituent entity in Maldives (highlight relevant):

1. 1.  Ultimate Parent Entity
   2. Surrogate Parent Entity
   3. Neither of the above 

In the case of the constituent entity in Maldives being neither Ultimate Parent Entity nor Surrogate Parent Entity, they should also provide the below details of the reporting entity that will be filing the CbC Report for the MNE Group.

1. 1. Full legal name of the reporting entity
   2. Tax residence of the reporting entity
   3. Full address of the reporting entity

The CbC Report to be filed in Maldives should be filed in a form identical to and applying the definitions and instructions contained in the standard template set out at Annex 3 of Chapter 5 of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (as the same may be modified from time to time).

Summarily, a CBC report consists of three tables:

• • Table 1 provides an overview of income, taxes, employees and assets of the MNE group allocated to each of the different tax jurisdictions in which the MNE group operates. Each line of the table reports the aggregated numbers relating to a particular tax jurisdiction.
  • Table 2 provides an overview of each constituent entity (including permanent establishments) of the MNE group, grouped according to the tax jurisdictions in which the entities are tax resident. The main business activities of each entity also need to be stated.
  • Table 3 allows the MNE group to provide any additional information it believes would be necessary or useful in interpreting and understanding the data provided in the CBC report.

The Country-by-Country Report required by this Regulation shall be filed with MIRA no later than 12 months after the last day of the Reporting Fiscal Year of the MNE Group.

Penalties for not filing a Country-by-Country Report shall be determined under Section 65 of the Tax Administration Act.

The CbC Reports shall be filed for Reporting Fiscal Years commencing on or after 1 January 2021.

Entities can email MIRA at [email protected] for further clarifications.