Country-by-Country Reporting - Notification

Hlavní informace

As a Czech member entity of a multinational group of enterprises, you are obliged to submit a country-by-country notification to the Specialized Tax Office.

Týká se vás to pokud

You are a member entity of a multinational group of enterprises, i.e. a separate accounting entity that is

• included in the consolidated financial statements of the group, or would be included in it if the shares or similar securities representing an interest in that entity were traded on a regulated market, including a similar market abroad; or
• excluded from the consolidated financial statements of the group because of its size or significance.

A Czech member entity of a multinational group of enterprises means a member entity of that group from the Czech Republic.

Multinational group of enterprises means a group of enterprises comprising:

• legal persons or entities without legal personality which are subject to taxation by reason of their registered office or place of management in different states or jurisdictions, or
• a legal person or entity without legal personality which, in addition to being taxed by reason of its registered office or place of management, is also subject to taxation in respect of activities carried out through a permanent establishment in a different state or jurisdiction.

A group of enterprises is a multinational group of enterprises in the reporting period if its total consolidated revenue stated in the consolidated financial statements of that group for the reporting period immediately preceding the relevant reporting period exceeds EUR 750 million (or the equivalent amount in the currency in which these statements are drawn up, converted at the average of the exchange rates published by the European Central Bank for January 2015).

Kdy službu řešit

The notification shall be made no later than by the end of the reporting accounting period in which the entity became a Czech member entity of a multinational group of enterprises.

Doplňující informace

Jaký má služba benefit

By complying with the legal reporting obligation on time, you will avoid the penalty that would have been imposed if you had not complied on time.

Možnosti odvolání

It is not possible to appeal against this service.

Sankce

The tax administrator may impose a fine on a Czech member entity of a multinational group of enterprises for failure to comply with an obligation of a non-monetary nature if it breaches the obligation to

• keep documents,
• request the ultimate parent entity of this group for cooperation.

A fine up to CZK 500,000 may be imposed by the tax administrator on anyone who fails to fulfil the registration, reporting or another notification obligation set out by tax law or the tax administrator.

Fines for non-fulfillment of certain obligations arising from the Act on International Cooperation in Tax Administration are not regulated by this Act, and the provisions of the Tax Code "Fine for a Failure to Fulfil an Obligation of a Non-monetary Nature" are therefore used.

Časté dotazy

Where can I find more information on Country-by-Country Reporting?

Frequently asked questions and answers on Country-by-Country Reporting can be found on the website of the Financial Administration of the Czech Republic.