Barbados joined the Global Forum in 2009. Barbados underwent its Second Round of EOIR Peer Review in 2020 (Barbados’ 2020 Report),1 which assessed its legal and regulatory framework in force as at 20 December 2019 and its practical implementation, including in respect of EOI requests received and sent, during the review period from 1 July 2015 to 30 June 2018. Barbados received an overall rating of Partially Compliant. Subsequently, Barbados underwent a Supplementary EOIR Peer Review in 2022 (Barbados’ 2022 Supplementary Report),2 which assessed its legal and regulatory framework in force as at 19 August 2022 and its practical implementation, including in respect of EOI requests received and sent, during the review period from 1 July 2018 to 30 June 2021. The overall rating of Barbados was upgraded to Largely Compliant, and the individual Elements were rated as follows:
Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025
Barbados
Copy link to Barbados|
A.1 |
A.2 |
A.3 |
B.1 |
B.2 |
C.1 |
C.2 |
C.3 |
C.4 |
C.5 |
Overall |
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Determinations |
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i.p.b. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
i.p. |
n.a. |
LC |
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Ratings |
PC |
PC |
LC |
LC |
C |
C |
C |
C |
C |
C |
Status of implementation of recommendations issued in the peer review report
Barbados received ten in-box recommendations in relation to Elements A.1, A.2, A.3, B.1 and C.5.
This monitoring report assesses the actions taken by Barbados to address the recommendations issued in its Supplementary EOIR Peer Review Report, and the peer input received for the monitoring period 2023-2024.
The report concludes that eight recommendations are “in the process of being addressed”, and two recommendations “have not been addressed”, and advises on actions required.
Element A.1: Availability of ownership and identity information
1. Availability of accurate and up-to-date beneficial ownership information
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Recommendation (A.1, framework) |
Consistent guidelines should be available to ensure that all entities, arrangements and AML-obliged persons comply with their requirements to identify beneficial owners. Barbados should ensure that, in practice, where no natural person meets the definition of a beneficial owner, the identification of the senior managing official as the beneficial owner is made in accordance with the standard. Barbados should ensure that adequate, accurate and up-to-date beneficial ownership information is available for all relevant legal entities and arrangements in line with the standard. |
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Underlying factor |
In Barbados, all companies incorporated under the Companies Act and foreign companies carrying out an undertaking in Barbados are required to maintain up-to-date records of their beneficial owners. However, there is no requirement in the Barbadian law on the frequency for the review or the update of beneficial owner information for partnerships and trusts. While the principal elements required by the standard with respect to the identification of beneficial owner(s) of legal entities are present, the requirement to identify persons holding a senior managerial position when no beneficial owner is identified is not contemplated in the definition. In accordance with the Companies Act, companies are also required to submit an annual statement by way of the annual return which certifies that accurate and up-to-date beneficial ownership information was maintained for the preceding year, at the registered office of the company. However, the compliance with this obligation is very low (27% in 2021). Although companies must maintain up-to-date records of their beneficial owners, the system in place does not ensure that changes in beneficial ownership are brought to their attention. A second source of beneficial ownership information relies on AML-obliged persons. Beneficial ownership information should be updated by the AML-obliged persons throughout the business relationship. However, there is no specified frequency for updating beneficial ownership information. In addition, the beneficial ownership information may not be available in all cases, as there is no requirement for all legal persons and arrangements to engage AML-obliged persons. Finally, the binding guidelines applicable to legal entities, legal arrangements and AML-obliged persons are inconsistent. (see paragraphs 37, 62, 65, 73, 76-77, 80-81, 116 and 121 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that compliance with filing obligations has increased from 27% in 2021 to 89.9% in 2022, linked to the clean-up of the register to eliminate inactive companies which started in 2022. The Anti-Money Laundering Authority guidelines have been aligned with the other guidelines with respect to the threshold for controlling ownership interest. The amended Corporate Affairs and Intellectual Property Office Guidelines (2025) state that senior managing officials should be identified as beneficial owners when no other natural person can be identified, and the Financial Services Commission guidelines are in the process of being amended accordingly. Barbados has introduced specified frequencies for the updating of beneficial ownership information. |
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Conclusion |
Barbados has made progress to address the recommendation. The clean-up of the register is a positive measure that has resulted in better compliance rates with obligations to declare maintaining beneficial ownership information at a registered office. The Anti-Money Laundering Authority guidelines have been aligned with the other guidelines on the threshold for controlling ownership interest. The change in the Corporate Affairs and Intellectual Property Office guidelines, allowing companies to identify a senior managerial natural person where no individual meets the definition of beneficial owner through ownership or control, is a suitable measure. Similar changes are in the process of being implemented in the Financial Services Commission guidelines. Updating requirements with specific timeframes have also been introduced. Nevertheless, the actions reported by the authorities do not cover all the aspects that had been identified as needing improvement. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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2. Implementation of supervisory and enforcement measures to ensure compliance with identity, legal and beneficial ownership filing and record keeping obligations
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Recommendation (A.1, practice) |
Effective supervisory and enforcement measures should be taken to ensure that all entities comply with their requirements to maintain identity and ownership information. |
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Underlying factor |
Although penalties for non-compliance with identity and ownership filing and record keeping obligations have been introduced into Barbadian law, they are not effectively applied in practice. (see paragraphs 82 to 96 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that stricter penalties are available for non-compliance with beneficial ownership identification and record keeping obligations under the amended Companies Act. As part of enforcement actions, the 14 510 companies on the company register were risk-rated for compliance with beneficial ownership identification and record keeping obligations. Four non-compliant companies were sanctioned with fines and one company was referred to the Director of Public Prosecution due to non-payment of the fine. The risk-rating is an ongoing process. In November 2022, the International Business Unit issued a Notice of Imposition of Pecuniary Penalties for Beneficial Ownership deficiencies to a Corporate and Trust Service Provider, resulting in a fine and provision of evidence for remediation of the deficiencies. |
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Conclusion |
Barbados has made progress to address the recommendation. It has put in place a risk-based supervisory system and provided evidence of the application of sanctions. The submissions reflect actions taken in respect of companies identified as high risk, but more evidence would be needed to reflect the levels of compliance by entities across risk categories, types of violations noted and application of sanctions where appropriate. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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3. Expansion of supervision and enforcement actions to cover smaller companies and general partnerships
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Recommendation (A.1, practice) |
Barbados is recommended to continue and enlarge its enforcement efforts to all entities with the implementation of a comprehensive and effective supervision and enforcement programme to ensure the availability of accurate and up-to-date legal and beneficial ownership information in line with the standard. |
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Underlying factor |
The Compliance Units under the International Business Unit and the Anti Money Laundering Authority have been recently set up. Regulatory cycles have started on companies with an annual revenue above BBD [Barbadian dollars] 1 million (EUR 439 898) through the monitoring of their corporate and trust service providers. However, the supervision of companies under this threshold, representing around 90% of all companies in Barbados, and of general partnerships, where the engagement with corporate and trust service providers is not mandatory, remains very limited. (see paragraphs 79 and 90 of the Barbados’ 2020 Report and paragraphs 86 to 96 and 108 to 116 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that following a register clean-up, all companies with annual revenue below BBD 1 million (EUR 439 898) were risk-rated against their obligation to maintain ownership information. Subsequently, 100% of high-risk companies and 30% of medium-risk companies were inspected and sanctions applied for non-compliance. All medium-risk companies that were inspected were found to be compliant. The supervision process is ongoing. Partnerships which engage a Corporate and Trust Service Provider or another AML-obliged person are covered by the supervisory processes of the International Business Unit and the Anti-Money Laundering Authority Compliance Unit, respectively, both of which have included enforcement actions. |
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Conclusion |
Barbados has made progress to address the recommendation. A risk-based approach to supervision has led to inspections of all high-risk companies and a third of medium-risk companies. There is evidence of enforcement actions in the form of pecuniary sanctions and strike-offs. The submissions reflect actions taken in respect of companies identified as high risk, but more evidence would be needed to reflect the levels of compliance by entities across risk categories, types of violations noted and application of sanctions where appropriate. No actions have been reported with regards to the supervision of partnerships that do not engage a service provider. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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4. Availability of legal and beneficial ownership information on inactive companies
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Recommendation (A.1, practice) |
Barbados should review its system whereby a significant number of noncompliant companies remain with legal personality on the Commercial Register and should implement appropriate supervision. |
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Underlying factor |
The significant number of non-compliant, and potentially inactive, companies (at least 63% of entities registered with the Commercial Register) that maintain legal personality but do not comply with their filing obligations raises concerns that updated legal and beneficial ownership information might not be available in all cases. (see paragraphs 37 and 101 to 106 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that through a register clean-up (which is ongoing), around 60% of the initial population of companies had been struck off by the end of 2024, reducing the risks related to inactive companies. This has resulted in higher compliance rates with the annual return filing obligations. While after strike-off, a company’s status as a registered entity is revoked and it loses legal personality, the company’s and every director’s liability may be enforced as before. Companies may apply for restoration after being struck off, subject to the provision of outstanding annual returns and other documents and settlement of penalties and fees. The person granted custody of the documents and records of a dissolved company must keep those in Barbados for six years following dissolution. |
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Conclusion |
Barbados has made progress to address the recommendation. The company register clean-up has been an important step and has resulted in improved compliance rates for filing of annual returns. However, companies can continue to become inactive, and the risk of their non-compliance and the non-availability of legal and beneficial ownership information remains. Since the issue of a large number of inactive companies continuing their legal personality in the company register has been a persistent issue in the past, the ongoing nature of the actions taken to ensure the integrity of the company register should be reflected over a longer timeframe and be supported through appropriate information (including statistical information on oversight activities). Barbados should report further substantive progress in the next self-assessment. |
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Status determined |
In the process of being addressed. |
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Actions required |
In its next self-assessment, Barbados should –
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Element A.2: Availability of accounting information
5. Adequate oversight over entities’ compliance with accounting record keeping obligations
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Recommendation (A.2, practice) |
Barbados is recommended to ensure that there is adequate oversight of the compliance of all entities with their accounting obligations. |
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Underlying factor |
Barbados does not have a regular system of oversight in place with respect to all entities. As less than 40% of the entities are registered with the Barbados Revenue Authority, the availability of accounting records may not be ensured through the related tax audit regime. (see paragraphs 134 to 140 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
The company register has been cleaned up and a crosschecking exercise between the register and the tax authority has led to more overlap. Barbados reported that a number of entities were audited against compliance with the Income Tax Act with regards to the obligation to retain accounting records. Amendments to the Income Tax Act to require all companies registered on the company register to file corporate tax returns are in the process of being put into place. |
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Conclusion |
Barbados has made progress to address the recommendation. The company register clean-up and the crosschecking exercise between the register and the tax authority mean the tax audit regime is better placed to examine availability of accounting records. It remains unclear how many entities were subject to audits and what the outcomes were. The amendments regarding the obligation for all companies to file corporate tax returns are yet to be passed and implemented. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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6. Application of sanctions to ensure availability of accounting information
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Recommendation (A.2, practice) |
Effective enforcement measures should be taken to ensure that all entities comply with their record-keeping requirements. |
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Underlying factor |
No sanctions have been applied for any violation of record-keeping obligations. Although sanctions exist, no authority has yet applied them for failing to maintain records as required. (see paragraphs 136, 138 and 141 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported proposed amendments to the Income Tax Act in the form of pecuniary penalties for failure to maintain or provide information on accounting records. The amendments remain under review. Barbados did not report the application of any sanctions. |
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Conclusion |
No progress has been reported on addressing the recommendation. Barbados is urged to address the recommendation and report substantive progress in its next self-assessment. |
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Status determined |
Has not been addressed |
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Actions required |
In its next self-assessment, Barbados should –
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7. Availability of accounting information on inactive companies
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Recommendation (A.2, practice) |
Barbados should review its system whereby a significant number of non-compliant companies remain with legal personality on the Commercial Register and should implement appropriate supervision. |
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Underlying factor |
The significant number of inactive companies (at least 63% of entities registered with the Commercial Register) that maintain legal personality but do not comply with their filing obligations raises concerns that accounting information might not be available in all cases. Such entities are not subject to effective supervision. (see paragraphs 134 to 140 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that the clean-up of the corporate register has led to so far around 60% of the initial population having been struck off. Amendments to the Income Tax Act to require all companies, including those which have not carried out business in a given year, to file a corporate tax return are in the process of being put in place. |
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Conclusion |
Barbados has made progress to address the recommendation. The number of inactive companies on the register has been reduced significantly, with this being an ongoing process. An important amendment to the Income Tax Act requiring all companies to file corporate tax returns is yet to be enacted and enforced. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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Element A.3: Availability of banking information
8. Lack of specified frequency to update beneficial ownership information
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Recommendation (A.3, framework) |
Barbados should ensure that up-to-date beneficial ownership information on all bank accounts in line with the standard is available. |
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Underlying factor |
There is no specified frequency of updating beneficial ownership information, so there could be situations where the available beneficial ownership information is not up to date. (see paragraph 144 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that the Central Bank of Barbados reviews Financial Institutions’ risk-based processes for updating beneficial ownership information. It does not prescribe a specific frequency for updating the information. The Central Bank is still considering how to address the recommendation. |
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Conclusion |
Barbados has taken preliminary steps to address the recommendation but no material progress has been reported. It is urged to make substantive progress before the next self-assessment. |
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Status determined |
Has not been addressed |
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Actions required |
In its next self-assessment, Barbados should:
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Element B.1: Access to information
9. Application of compulsory access powers and imposition of sanctions
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Recommendation (B.1, practice) |
Barbados is recommended to use its compulsory powers whenever necessary to ensure that all requested information is obtained in a timely manner for exchange purposes. |
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Underlying factor |
Despite having sanctions for non-compliance with a request for information, the authorities of Barbados have not applied enforcement procedures in a streamlined and effective manner to ensure compliance by information holders. (see paragraph 146 of the Barbados’ 2020 Report and paragraphs 151 to 155 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
Barbados reported that it continued to use compulsory powers under the Income Tax Act, Section 76, to gather information. It reported on two concrete cases of use of access powers in 2025. |
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Conclusion |
Barbados has made progress to address the recommendation. It provided concrete examples of recent successful application of access powers. Previous cases of non-compliance or delayed compliance with information requests as well as the issue of response times remained unaddressed. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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Element C.5: Effective exchange of information
10. Status updates
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Recommendation (C.5, practice) |
Barbados should systematically provide an update or status report to its EOI partners within 90 days when the Competent Authority is unable to provide a substantive response within that time. |
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Underlying factor |
During the period under review, Barbados has not always provided status updates to its EOI partners within 90 days when the Competent Authority was unable to provide a substantive response. (see paragraphs 228 to 229 of the Barbados’ 2020 Report and paragraph 200 of the Barbados’ 2022 Supplementary Report for more information) |
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Summary of actions reported |
For the monitoring period 2023 and 2024, Barbados received 23 EOI requests, of which 15 were responded to within 90 days and 4 are still pending. Barbados reported having provided status updates or partial responses in all cases that could not be fully responded to within 90 days. A dedicated email account was created to improve communication with partners and Barbados was working on starting the use of the Common Transmission System. |
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Conclusion |
Barbados has made progress to address the recommendation. It has taken steps to improve communication with partners and reports providing status updates. One peer indicated difficulties in receiving a status update during the monitoring period. Barbados should report further progress in the next self-assessment. |
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Status determined |
In the process of being addressed |
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Actions required |
In its next self-assessment, Barbados should –
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EOIR experience
Over the monitoring period 2023-2024, Barbados received 23 requests and sent 1 request. Canada, Colombia and the United Kingdom were the top three partners in respect of incoming requests. Barbados reported providing full and final responses in 83% of all the received requests and indicated 17% as pending requests.
Out of the five members that provided peer input, three indicated having EOIR exchanges with Barbados during the monitoring period. They reported general satisfaction in respect of their EOIR experience with Barbados. However, one peer indicated concerns about missing information and the lack of a status update. There is a pre-existing recommendation on the issue of systematic provision of status updates, and in light of the peer input, Barbados is recommended to ensure status updates are systematically provided where required.
New developments having a bearing on the EOIR standard
No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Barbados or have otherwise come to light.
Next steps
Barbados should continue taking actions towards implementing the standard effectively.
The following next steps are expected from Barbados:
Submit the next self-assessment in 2028 under the second round of enhanced monitoring.
Views/response of the monitored jurisdiction
Barbados reaffirms its unwavering commitment to the Global Forum on Transparency and Exchange of Information for Tax Purposes and fully supports the objectives of the Enhanced Monitoring process. The jurisdiction remains actively engaged in strengthening its legal and regulatory framework and ensuring the consistent and effective implementation of the Exchange of Information on Request standard. This reflects Barbados’ dedication to the cooperative and collaborative approach to international tax matters that has become a hallmark of engagement with global partners.
In preparation for the next reporting cycle, Barbados will continue to advance key reforms, including the implementation of measures to enhance the availability and accessibility of beneficial ownership information, and to further improve the effectiveness of its exchange of information framework. These efforts underscore Barbados’ resolve to uphold the highest standards of transparency and international cooperation in tax matters.
Notes
Copy link to Notes← 1. OECD (2020), Global Forum on Transparency and Exchange of Information for Tax Purposes: Barbados 2020 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/fbb6ecef-en.
← 2. OECD (2022), Global Forum on Transparency and Exchange of Information for Tax Purposes: Barbados 2022 (Second Round, Supplementary Report): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/5b2561d4-en.