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The obligation for the Multinationals to submit the Country-by-Country report to the State Tax Inspectorate

Based on the legislation, the MNE situated within the European Union (hereinafter - EU) or with operations in the EU with total consolidated revenue equal or higher than 750 million EUR should submit the CbCR to the Tax Authority.

The CbCR should be submitted to the Tax Authority of the Member State:

  • in which the ultimate parent entity of the MNE Group is established or
  • the MNE may appoint one of group’s companies to submit the information to Tax Authorities on behalf of the parent company.

The CbCR should include information for every tax jurisdiction in which the MNE does business on:
  • the amount of revenue;
  • the profit before income tax;
  • the income tax paid and accrued;
  • the number of employees;
  • the stated capital;
  • the retained earnings;
  • the tangible assets.

The first country-by-country report shall be submitted for the Fiscal Year of the MNE commencing on or after 1 January 2016:
  • if the fiscal year starts on 1 January 2016, the CbCR should be submitted no later than 12 months after the last day of the reporting fiscal year of the MNE, i.e. till 31 December 2017 ;
  • if the financial year does not coincide with the calendar year, CbCR report for fiscal year starting in 2016, should be reported latest till the end of the first quarter of 2018.

The Member State will communicate the report to any other Member States, in which one or more Constituent Entities of the MNE are either resident for tax purposes, or are subjects to tax with respect to the business carried out through a permanent establishment.


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