We believe that you have been informed in Tax newsletter on Country by Country reporting in transfer pricing (“CbC Reporting”), we would like to bring to your attention that your Company might be obliged to file a CbC Reporting notification to the respective Slovak tax authority (see question 1 below to find out if notification applies to you).
The notification obligation has to be fulfilled by the corporate income tax return filing deadline (or postponed deadline) and applies to tax periods starting on or after 1 January 2016, e.g. notification obligation by 31 March 2017 in case of the 2016 tax period (calendar year). If your company applies financial year (tax period other than calendar year) which starts on or after 1 January 2016, the deadlines are adjusted accordingly.
We are ready to support your Company with gathering the necessary information, preparation/ filling of the notification should you be interested.
The key information you will have to find out for the purpose of CbC Reporting notification purposes are:
- Whether your Company (Slovak tax resident, Slovak Branch or a Slovak permanent establishment) is part of a multinational Group with consolidated group revenues reaching EUR 750 million in the preceding tax year (in 2015). If so, the notification obligation applies by the corporate income tax return filing deadline (or postponed deadline) of the tax period starting on or after 1 January 2016.
- If the answer to question 1 is yes, is there a company within your MNE Group which will file the CbC Report for the 2016 tax period? Please obtain the name, address, tax identification / identification number and country of residency of the company within your Group which will be filing the 2016 CbC report.
- If your group qualifies under the question 1 and none of the companies within your Group will file the 2016 CbC Report (as per question 2) please find out who is the Ultimate Parent Entityof your Group and what is the country of its tax residency (Ultimate Parent Entity is an entity which has such direct or indirect participation in other entity/ies of your Group that it qualifies for preparing Consolidated Financial Statements of the Group and at the same time such entity is not owned by any other company of your Group).
The above questions/answers will help us gather the main information necessary for the notification obligation of you Company. Please let Mazars know as soon as possible whether you would require their assistance as well as provide answers to the above. Feel free to contact us in case of any questions.