{"id":662,"date":"2023-05-10T11:10:48","date_gmt":"2023-05-10T09:10:48","guid":{"rendered":"http:\/\/www.red.tax\/?p=662"},"modified":"2023-06-28T15:14:44","modified_gmt":"2023-06-28T13:14:44","slug":"titel-van-de-case-blog-of-artikel-1-komt-hier-te-staan-2","status":"publish","type":"post","link":"https:\/\/www.red.tax\/en\/titel-van-de-case-blog-of-artikel-1-komt-hier-te-staan-2\/","title":{"rendered":"Country-by-Country Reporting will open its doors"},"content":{"rendered":"

In the last couple of years, the general public has become more interested in the tax behavior of multinational groups. We have witnessed increasing public claims that big multinational groups pay low effective tax rates, resulting in intensified media coverage whereby triggering controversial discussions over the effective tax rates of companies like Starbucks, Apple and Fiat.<\/p>\n

Along with such public claims, many tax regulations have been implemented or become more stringent to tackle the so-called term \u201caggressive tax planning\u201d. In 2016, the OECD set out a new obligation to file the Country-by-Country Reporting (CbCR) as one of the measures implemented within Action 13 of the Basis Erosion and Profit Shifting (BEPS) Project. As stated in the OECD Guidelines, this obligation provided tax administrations with a consistent and global template for a high-level view of the allocation of income and taxes paid across jurisdictions. At the same time, it provided the tax administrations with access to relevant information to assess transfer pricing risks beyond what would have been achieved solely under their domestic law.<\/p>\n

\u201cName and shame\u201d approach?<\/strong><\/h6>\n

Now \u2013 shortly following the implementation of the CbCR requirement for multinational companies \u2013 this obligation will be extended, requiring groups to prepare a public CbCR that could constitute a \u201cname and shame approach\u201d. In this regard, the EU Parliament accepted the draft version of the CbCR Directive and made it publicly available in the Official Journal of the European Union in December 2021.<\/p>\n

According to Article 48b of the CbCR Directive, multinational groups active in the European Union and stand-alone entities with presence in more than one Member State whose consolidated global revenues are higher than EUR 750 million in the last two business years must provide the public with the CbCR starting fiscal year 2025.<\/p>\n

Article 48c of the Public CbCR Directive lists the information to be included in the public CbCR by third states and each EU Member State \u2013 on an aggregated level. Country specific information shall consist of the following:<\/p>\n