Six Caribbean jurisdictions have no outstanding recommendations under BEPS Action 13, but five have yet to legislate, according to the latest OECD peer review of country-by-country reporting.
The Organisation for Economic Co-operation and Development (OECD) and G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) published its Compilation of 2026 Peer Review Reports on Country-by-Country Reporting (CbCR) on 19 October 2026, showing progress across the Caribbean but with clear gaps.
The report is the latest annual assessment of how 142 Inclusive Framework members are implementing BEPS Action 13. It reviews implementation as of April 2026.
Global picture
More than 120 jurisdictions have introduced legislation requiring multinational enterprise (MNE) groups to file country-by-country reports. This covers almost all groups with consolidated group revenue at or above the EUR 750 million threshold. The remaining members are working to finalise their domestic legal frameworks with OECD support.
Where legislation is in place, implementation is largely consistent with the Action 13 minimum standard. More than 5,100 bilateral relationships for exchanging CbC reports are now in place.
The minimum standard requires tax administrations to collect and share detailed information on large MNEs. This includes revenue, profit before income tax, and income tax paid and accrued, as well as stated capital, accumulated earnings, number of employees and tangible assets, all broken down by jurisdiction.
Fully compliant jurisdictions
Six Caribbean jurisdictions have complete domestic legislation, exchange mechanisms and appropriate use controls, with no recommendations for improvement:
- Antigua and Barbuda: fiscal years ending on or after 31 December 2025; threshold of USD 850 million.
- Aruba: fiscal years commencing on or after 1 January 2019; threshold of AWG 1,500 million.
- Barbados: fiscal years commencing on or after 1 January 2021; threshold of USD 850 million.
- Belize: fiscal years commencing on or after 1 January 2019; threshold of USD 850 million.
- Curaçao: fiscal years commencing on or after 1 January 2018; threshold of NAFl 1.5 billion.
- Dominican Republic: fully meets all terms of reference; threshold of DOP 38,800 million.
Non-reciprocal jurisdictions
Several Caribbean financial centres operate as non-reciprocal jurisdictions. They require resident Ultimate Parent Entities (UPEs) to file CbC reports and exchange them with foreign partners, but do not receive reports from other tax authorities or require local filing:
- Anguilla: fiscal years starting on or after 1 January 2019; threshold of USD 850 million.
- Bahamas: fiscal years starting on or after 1 January 2018; threshold of USD 850 million. A monitoring point remains regarding legal clarity on local filing deactivation provisions.
- British Virgin Islands: fiscal years starting on or after 1 January 2018; threshold of EUR 750 million.
- Cayman Islands: an early adopter, with rules effective for fiscal years starting on or after 1 January 2016; threshold of USD 850 million.
- Montserrat: fiscal years starting on or after 1 January 2024; threshold of EUR 750 million.
- Trinidad and Tobago: first reporting fiscal year commences on or after 20 December 2024; threshold of USD 850 million; local filing suspended.
- Turks and Caicos Islands: fiscal years starting on or after 1 January 2020; threshold of USD 850 million.
Recent legislative progress
Dominica introduced CbC filing requirements for fiscal years starting on or after 1 January 2025. It also activated exchange relationships under the Multilateral Competent Authority Agreement (MCAA), leading to the removal of past overarching recommendations.
However, recommendations remain for Dominica to restrict local filing to permitted circumstances and to put appropriate use controls in place before initial exchanges.
Jurisdictions yet to legislate
Five Caribbean jurisdictions have not yet introduced domestic legal frameworks to enforce CbC reporting obligations:
- Grenada
- Haiti
- Jamaica
- Saint Lucia
- Saint Vincent and the Grenadines
All five have standing recommendations to enact a domestic legal framework, sign qualifying competent authority agreements, establish exchange procedures and implement controls for appropriate use.
Opted-out jurisdiction
Saint Kitts and Nevis opted out of the peer review in accordance with the terms of reference. It confirmed that no resident entities serve as the UPE of an MNE group above the threshold and that local filing is not imposed.
Next review
The BEPS Action 13 peer review is an annual process. The next report will be released in the third quarter of 2027.
For the Caribbean, the review shows a region where most jurisdictions have built the legal and exchange foundations required, while a smaller group must still enact legislation to meet the minimum standard.
