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.
14.07.17
