In connection with the implementation of the European Union Directive DAC IV, an obligation to compile a so-called country-by-country report has been introduced.
This obligation applies to companies within multinational groups whose consolidated earnings for the immediately preceding period exceed EUR 750 million. Periods commenced on or after 1 January 2016 are considered the first reporting period.
In each subsequent period, it is necessary to verify whether a group registered for country-by-country report filing still meets the relevant conditions (in particular, the amount of consolidated revenues as above). Further, it is necessary to verify whether a group that has not filed the country-by-country report previously is not newly obliged to do so.
Any changes in the fulfilment or non-fulfilment of conditions for the country-by-country report filing have to be reported to the tax administrator. It is also necessary to report to the tax office any changes in the registered data within 15 days. If there is no change in the previously reported data, there is no need to undertake any further steps.