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

If you are the 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 from the end of the reported accounting period of the multinational group of enterprises. If the first reporting period is the calendar year 2024, then do not forget to submit the report for the year 2024 by December 31, 2025.

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 country-by-country notification must be filed no later than the end of the reported accounting period in which the accounting entity became a Czech member entity of the multinational group of enterprises. If the first reporting period is the calendar year 2025, then you have to submit the notification by December 31, 2025.

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.