At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Barbados Revenue Authority (BRA). Summaries are simplified; check the linked official source before relying on them.
The law
#Barbados has no dedicated transfer pricing law or regulations. The only rules are in the Income Tax Act, Cap. 73. Section 29(1) deems a purchase and sale between parties where one controls the other, or between relatives, that is not at arm's length to take place at fair market value. Section 29(2) lets the Commissioner disregard or modify a transaction whose main purpose is to artificially reduce assessable income. The government has said a transfer pricing law based on the OECD Guidelines is coming, but no transfer pricing bill is on the Parliament bill list as of 27 October 2026. The latest Income Tax amendment (Act 2025-30) adds economic substance rules, not transfer pricing rules.
Documentation
#There is no master file, local file, or transfer pricing form. Every business must keep records and books of account in Barbados and keep them until the Commissioner allows disposal (Income Tax Act s. 75). Country-by-Country reporting is the only transfer pricing style filing, and it is a separate Act.
Methods
#No methods are prescribed. Section 29(1) uses fair market value for purchases and sales between controlled or related parties. Section 29(2) is an anti-avoidance rule, not an arm's length method. Until a law is passed, the OECD Guidelines have no statutory force in Barbados.
Penalties
#There are no transfer pricing penalties. A section 29 adjustment is assessed under the general rules: a late return costs a fixed penalty plus 5% of the tax assessed (s. 67(1) and (1A)), late tax costs 5% plus interest of 1% a month (s. 67(5) and (6)), and knowing evasion carries a penalty equal to the tax evaded (s. 67(8)). Country-by-Country failures cost BBD 10,000 plus BBD 5,000 a day (CbC Act s. 17).
Pillar Two
#The Corporation Top-up Tax Act, 2024-16 (in force 24 May 2024) is a qualified domestic minimum top-up tax (QDMTT) at 15%. It applies to fiscal years starting on or after 1 January 2024 for Barbados entities of groups with revenue of EUR 750m or more in 2 of the 4 years before the tested year. For the first fiscal year starting on or after 1 January 2024, top-up tax is due only if the group's Barbados income is subject to an IIR or UTPR in another country (s. 5(4)). The Act has no IIR or UTPR of its own. Each entity gives a one-time notice within 12 months of its first in-scope year end (BBD 10,000 penalty). The GloBE Information Return (GIR) is due 15 months after year end, or 18 months for the first year (S.I. 2026 No. 65 reg 4). Payment is due on the same date (reg 8), and the BRA says the Domestic Top-Up Tax return is too. Late return or payment costs BBD 1,000 plus 1% a month.
Other rules
#Corporation tax return: due 15 March for fiscal periods ending 1 January to 30 September, and 15 June for periods ending 1 October to 31 December, in the year after the income year (Income Tax Act s. 52). Tax not yet paid is due the same day (s. 66). Monthly prepayments are due by the 15th of each month from income year 2025 (BRA OGC No. 2/2025). The BRA extended the return date in 2025 and 2026 because of system problems. Country-by-Country report: USD 850m threshold, due 12 months after year end. Under Interpretation Act Cap. 1 s. 39(5), a deadline that falls on a Sunday or public holiday moves to the next day that is neither. Saturday is not a rest day.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Country-by-Country notification Each Barbados-resident constituent entity must tell the Competent Authority, by the last day of the reporting fiscal year, whether it is the ultimate parent or surrogate parent, or else who the reporting entity is and where it is resident (CbC Act s. 5). A surrogate parent also gives written notice before the report due date (s. 4(5) and (6)). Failure costs BBD 10,000, plus BBD 5,000 a day if the failure continues after that penalty falls due (s. 17). | Last day of the fiscal year (e.g. Dec 31, 2025) | MNE groups with consolidated revenue of USD 850m or more in the fiscal year before the reporting year. The Act sets USD 850m, not the usual EUR 750m. | Income Tax (Country-by-Country Reporting) Act, 2021-27 (BRA) |
| 2 | Corporation tax return (income year return, filed on TAMIS) Income Tax Act s. 52(1)(a): 15 March of the next year if the fiscal period ends between 1 January and 30 September, and 15 June of the next year if it ends between 1 October and 31 December. A date on a Sunday or public holiday moves to the next day that is neither (Interpretation Act s. 39(5)). The BRA extended filing for income year 2024 to 31 July 2025 for all year ends (press release of 13 June 2025), and for income year 2025 to 15 April 2026 for January to September year ends (OGC No. 3/2026). Check the BRA site each spring for a new extension. Late filing costs a fixed penalty plus 5% of the tax assessed (s. 67). | Fixed calendar date (e.g. Jun 15, 2026) | Every company that carried on a business in the income year, whether or not it had income. | Income Tax Act, Cap. 73, s. 52 (BRA); BRA Guidance Note OGC No. 3/2026 |
| 3 | Corporation tax: balance of tax due Any part of the tax estimated in the return that is still unpaid is due on the statutory return date (Income Tax Act s. 66(1)). For income year 2025 the BRA moved payment for January to September year ends to 27 March 2026, earlier than the extended filing date of 15 April 2026 (OGC No. 3/2026). The 2025 filing extensions for income year 2024 did not mention payment. Late payment costs 5% of the unpaid tax plus interest of 1% a month (s. 67(5) and (6)). | Fixed calendar date (e.g. Jun 15, 2026) | Every company with tax still unpaid after prepayments. | Income Tax Act, Cap. 73, ss. 66 and 67 (BRA); BRA Guidance Note OGC No. 3/2026 |
| 4 | Country-by-Country report Due 12 months after the last day of the reporting fiscal year (CbC Act s. 6(1)), filed on the BRA AEOI portal in the format the Commissioner directs (s. 7). The first reporting year began on or after 1 January 2021. The AEOI portal was closed for maintenance in June 2026 and again in August 2026, so check it is open before the due date. Failure costs BBD 10,000, plus BBD 5,000 a day if the failure continues after that penalty falls due (s. 17). A knowingly false report can bring a BBD 50,000 fine or up to 10 years in prison (s. 14). | 12 months after year end (e.g. Dec 31, 2026) | Barbados-resident ultimate parents of groups at or above USD 850m. Other Barbados entities file only if the parent country does not require or exchange the report, or the Competent Authority reports a systematic failure. | Income Tax (Country-by-Country Reporting) Act, 2021-27 (BRA) |
| 5 | GloBE Information Return (GIR) Due 15 months after the fiscal year end, or 18 months for the first fiscal year (a year that starts on or after 1 January 2024 but before 1 January 2025, or the first year the group is in scope and has not filed a GIR elsewhere). Regulation 4(1) of S.I. 2026 No. 65. For a December 2024 year end the date was 30 June 2026, and for December 2025 it is 31 March 2027. One designated filing entity may file for all Barbados entities. A GIR filed in another country that exchanges it with Barbados replaces the local GIR (reg 5). The BRA said it will not charge penalties or interest if a December 2024 year end filing is made by 30 September 2026 (guidance note ORC No. 1/2026 as printed, issued 31 July 2026), but the due date did not change. Filed on the BRA AEOI portal. The 18 month rule for later first-in-scope groups cannot be shown by the tool, which uses the 2024 transition rule. | 15 months after year end (e.g. Mar 31, 2027) | Barbados entities (and joint ventures) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (Corporation Top-up Tax Act s. 6(2)). | S.I. 2026 No. 65, Corporation Top-Up Tax (Designation of Competent Authority and GloBE Information Returns) Regulations, 2026 |
| 6 | Notice that the GIR was filed in another country If the ultimate parent or a designated filing entity filed the GIR in a country that exchanges GIRs with Barbados, the Barbados entity must tell the Commissioner by the GIR due date (reg 5(2)). If the BRA has not received the GIR by the exchange date, the entity has 30 days from the BRA's notice to file locally (reg 5(3)). | With GloBE Information Return (GIR) (e.g. Mar 31, 2027) | Barbados entities (and joint ventures) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (Corporation Top-up Tax Act s. 6(2)). | S.I. 2026 No. 65, Corporation Top-Up Tax (Designation of Competent Authority and GloBE Information Returns) Regulations, 2026 |
| 7 | Domestic Top-Up Tax return (QDMTT, on TAMIS) One local entity files a return for the whole Barbados DMTT group on TAMIS, using the 'Top Up Tax First Year' return type for the first year, with a list of the local entities (Act s. 46). The Act does not define the return date. The BRA says it is the same date as payment, which reg 8(1) sets at the GIR due date (OGC No. 8/2026). A nil return must give the reason no tax is due. Failure costs BBD 1,000 plus 1% a month (s. 46(8)). For the first fiscal year from 1 January 2024, top-up tax applies only if the group's Barbados income is taxed under an IIR or UTPR elsewhere (s. 5(4); OGC No. 13/2026). | With GloBE Information Return (GIR) (e.g. Mar 31, 2027) | Barbados entities (and joint ventures) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (Corporation Top-up Tax Act s. 6(2)). | Corporation Top-up Tax Act, 2024-16, s. 46 (BRA); BRA Guidance Note OGC No. 8/2026 |
| 8 | Top-up tax payment (QDMTT) Due on the specified return date, which is the GIR due date: 18 months after the first fiscal year and 15 months after later years (Act s. 47(1); reg 8; OGC No. 8/2026). Filing in another country does not extend it (reg 8(2)). Paid in BBD or USD through TAMIS or wire. Late payment costs BBD 1,000 plus 1% a month (s. 47(4)). The BRA charges no penalty or interest for a December 2024 year end paid by 30 September 2026, but the due date was 30 June 2026. | With GloBE Information Return (GIR) (e.g. Mar 31, 2027) | Barbados entities (and joint ventures) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (Corporation Top-up Tax Act s. 6(2)). | BRA Guidance Note OGC No. 8/2026: Payment of Top-Up Tax (GloBE Minimum Tax) |
| 9 | Corporation tax monthly prepayments Prepayments are due by the 15th day of each calendar month and are paid through the BRA Global Relations Portal (BRA guidance OGC No. 2/2025, which refers to OGC No. 04/2025). The older law (Income Tax Act s. 64B) set prepayments of 50% of the previous year's tax on 15 September for January to September year ends, and on 15 December and 15 March for October to December year ends. How the monthly amount is worked out was not read from an official page. | See note | Companies that must prepay tax. The BRA set a monthly method from income year 2025. | BRA Guidance Note OGC No. 2/2025: Revised Extension of Corporation Tax Filing Deadline and Update on Monthly Prepayments |
| 10 | Top-up tax notification (one-time registration) A qualifying entity gives notice, on the Top-Up Tax Registration Form on the BRA Global Relations Portal, within 12 months after the last day of the first fiscal year in which it is a qualifying entity (Corporation Top-up Tax Act s. 45(1)). The BRA let notices due during 2025 or by 6 March 2026 be filed by 31 March 2026 and treated as on time (OGC No. 2/2026). Changes and cessation must be notified within 12 months of the end of the fiscal year (s. 45(3) and (4)). Failure costs BBD 10,000 (s. 45(5) and (6)). The tool shows this notice only for the 2024 transition year; a group that enters scope later must also file it. | One-time: due only for the first year in scope | Barbados entities (and joint ventures) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (Corporation Top-up Tax Act s. 6(2)). | Corporation Top-up Tax Act, 2024-16, s. 45 (BRA); BRA Guidance Notes OGC No. 1/2026 and 2/2026 |
| 11 | Notice of the designated filing entity Where a designated filing entity files the GIR for the group, each qualifying entity must tell the Commissioner who it is at least 30 days before the GIR due date (reg 4(4)(b)), and promptly if a new one is appointed. | See note | Barbados entities (and joint ventures) of MNE groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 fiscal years before the tested year (Corporation Top-up Tax Act s. 6(2)). | S.I. 2026 No. 65, Corporation Top-Up Tax (Designation of Competent Authority and GloBE Information Returns) Regulations, 2026 |
Official texts
#- Corporation Top-up Tax Act, 2024-16 (Not confirmed. The BRA site says all rights reserved, its terms page could not be read, and the Copyright Act (Cap. 300) text read has no clear exemption for enacted laws.)
- S.I. 2026 No. 65, Corporation Top-Up Tax (Designation of Competent Authority and GloBE Information Returns) Regulations, 2026 (Not confirmed (same reason). Published in the Official Gazette of 17 June 2026.)
- Income Tax (Country-by-Country Reporting) Act, 2021-27 (Not confirmed (same reason).)
- Income Tax Act, Cap. 73 (L.R.O. 2007 edition on the BRA site) (Not confirmed (same reason).)