STEP Barbados: Is Barbados ready to meet its 2018 CRS deadline?

The Barbados Branch of the Society of Trust and Estate Practitioners (“STEP”) hosted a seminar on the Common Reporting Standard, and its implications for Barbados on Thursday, 22 March 2018 with La-Tanya Edwards, a senior manager leading the Caribbean Tax Desk at the EY New York Office; and Javier Lemoine, Regional Senior Manager (Tax and Legal) and Imran Ali, Senior Tax Manager/International Tax Expert both of PwC Barbados.

The Common Reporting Standard (“CRS”) was developed in response to a G20 request and approved by the Council of the Organisation for Economic Co-operation and Development (OECD) in 2014. It calls on jurisdictions to obtain information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis with a view to minimising tax evasion.

Barbados enacted the Income Tax (Automatic Exchange of Information) Regulations, 2017 with a view to facilitating compliance with this international standard on 22 May 2017 but with retroactive effect from 1 January 2017. However, Barbados in 2017 requested an extension of the deadline to commence exchanging information to September 2018.

Edwards of EY introduced core concepts related to the CRS, and Lemoine and Ali discussed the local legislation, upcoming deadlines as well as practical implementation challenges. Lemoine, in particular, noted that challenges for reporting financial institutions include developing systems to continually audit their client portfolio, as well as introducing new client on-boarding procedures to identify reportable accounts. He further noted that challenges for the Barbados Revenue Authority, included implementing a system for local financial institutions to report their information, as well as to exchange the information required to be exchanged with tax authorities in other jurisdictions.

The Q&A session seminar was moderated by Tara Frater, Chairperson of STEP Barbados. Members of the audience expressed concern as to whether the Barbados Revenue Authority was, in fact in a position to exchange information this year. Frater remarked, “STEP Barbados is keenly interested to understand whether the Barbados Revenue Authority will be in position to commence exchange of information by September 2018. The sheer volume of information, the automated nature of the systems required and the multiple relationships to be managed with tax authorities in different languages will create unique challenges for us. We must urgently prepare ourselves to meet this challenge, as the consequences for failure to comply in time will be dire and may include blacklisting of Barbados – which adversely affects investment into Barbados.”

Frater also announced that Barbados will be hosting the STEP Caribbean Conference this year from May 7 to 9. She explained that this conference will provide excellent education and opportunities for its delegates. She expected the conference to have 250 delegates this year, both from Barbados and other international countries

Arlene Ross, Vice Chairperson of STEP Barbados announced that STEP would formally launch its Employer Partnership Programme, an employer accreditation programme, which is currently free of cost to employers for 3 years, through which training and development of employees would be facilitated at the upcoming STEP Caribbean Conference.