Country by Country Reporting and Notification

As the deadline imposed by the European Union for transposing the EU Directive 881 / 2016 regarding the mandatory automatic exchange of tax information (i.e. 4 June 2017) approached, EU Member States transposed all changes brought by this directive into their local laws at an accelerated pace.

The new regulations from each of the countries that transposed the EU Directive 881 / 2016 brings two new reporting obligations for companies that are part of a multinational group of companies with a consolidated turnover exceeding EUR 750 million, as follows:

(i) companies that have the obligation to submit a simple one-two pages notification about the entity within the group that will submit the full Country by Country Report; and

(ii) companies that have the obligation to submit the full Country by Country Report to the competent authorities from the countries where they are resident, namely companies that are in the position of ultimate parent companies of the group, surrogate parent companies, group delegated entities, and companies resident in countries that don’t have a working mechanism of automatic exchange of information.

How we can help?

We can entirely outsource and / or offshore the preparation and submission of the Country by Country Report and of the notification.

On the one hand, we can coordinate the whole process of gathering the data to fill in the notifications as well as to fill in the Country by Country Report.

On the other hand, we can fill in and prepare the xml Country by Country Report as well as the notifications that we will then send to your accountant to simply file them in the countries where it is necessary, or, if you want to, we can even file them with our own resources.

Moreover, having regard that the times when tax authorities will start to use in their risk analyses information from the Country by Country Reports, we can advise you on how to report the data and how to make corrections in the business model so as in the future you can know yourself safe.

Key benefits

Avoid fines and penalties

The EU Directive 881/2016 didn’t specify what should be the fines and penalties that companies should pay in case of failure to submit the Country by Country Report or the notification.

Nevertheless, when transposing the EU Directive 881/2016, most of the countries chose to include in their own legislation fines and penalties that are significant enough in some cases.

Therefore, by choosing to file the Country by Country Report and the notifications, significant fines and penalties could be avoided.

Highly specialized and cost effective

Our outsourcing and / or offshoring solutions for the preparation of the Country by Country Report and of the notifications are targeted to be offer you a highly effective solutions in these times of scarce internal resources and increasing cost-pressures.

We have experienced and competent transfer pricing consultants that can handle in an utmost efficient manner the entire process of gathering information, preparation of the Country by Country Report and of the notifications.

Assessment of the tax audit risk

Based on out experience in transfer pricing audits and in dealing with tax authorities, we can can bring real benefits in anticipating what are the risks borne by submission of the Country by Country Report.