Let us recall also “classic” Country-by-Country Reporting (CbCR) and the resulting obligations.
The CbCR is enshrined in the Act on International Cooperation and requires multinational groups of enterprises whose consolidated revenues for the previous accounting period exceeded EUR 750 million to compile and submit the so-called Report by country. Czech companies are obliged, as part of their CbCR obligations, to submit (i) Report and (ii) Notification.
The Report by Country must be submitted by the so-called reporting entity, which is usually the highest parent entity of the group, and will do so on behalf of the entire group. If the group specifies, the reporting entity can be a representative parent entity or a representative European entity. If the reporting entity is a Czech company, it is obliged to file a Report within 12 months after the end of the group’s reporting financial year.
A Czech company that is part of a multinational group of companies (which is obliged to CbCR) and is not a reporting entity is obliged to submit a Notification. The Notification informs the tax administrator which entity within the group submits the Country-by-Country Report. A Czech company is obliged to submit a Notification only once, unless there is a change in the reported data (e.g. a change in the reporting period, a change in the entity that submits the Report on behalf of the group or a change in contact details, etc.). The deadline for filing the Notification is by the end of the reporting period. In the event of a change in the reported data, the company is obliged to inform the tax administrator within 15 days of the change.
The Notification and the Report can only be submitted via the EPO application and cannot be sent to the tax administrator’s data box.
In the event of non-compliance with the reporting obligation, the taxpayer faces a fine of up to CZK 500 thousand.
If you are not sure as to whether this obligation applies to your company, do not hesitate to contact our experts.
