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Are you subject to Country-by-Country Reporting obligations?

09.10.2024

In terms of the automatic exchange of information in tax spheres, since 2017, selected companies operating as members of multinational groups have been required to draw up the so-called Country by Country Reporting (CbCR). This obligation only applies to multinational groups of companies that have consolidated annual revenues exceeding EUR 750 million.

If you are supreme (uppermost) parent entity of such a multinational group, you are required to file a so-called REPORT (OZNÁMENÍ in Czech), no later than 12 months after the end of the reported accounting period of the multinational group of enterprises. If the first reporting period is the calendar year 2023, then do not forget to submit the report for the year 2023 by December 31, 2024.

If you are part of such a multinational group, you are required to file a so-called NOTIFICATION (OHLÁŠENÍ in Czech), where you indicate your supreme parental entity, which will file the CbCR (report) for the whole group. The deadline for submitting the notification is set on the last day of the first reported accounting period. If the first reporting period is the calendar year 2024, then you have to submit the notification by December 31, 2024.

However, if you have already filed the notification in the past and there has been no change to the reported data (cease of the obligation to submit CbCR, change of the supreme parent entity, etc.), there is no need to do anything in relation towards the tax administrator. However, if there has been any change at your part, please do not forget that the deadline for notification of changes in the reported data is 15 days from the day the change occured.