Country-by-Country Reporting – Notification

Main information about the service

Does this apply to me?

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).

Service outcome

Compliance with the legal obligation to file a country-by-country reporting notification.

Service benefit

Ensuring the Specialised Tax Office is informed.

When to address the service

The notification shall be made within the following deadlines:

• new notification – 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,
• changes within 15 days from the day on which the change occurred,
• notification – termination of the obligation – by the end of the reporting period in which the entity ceased to be a member of a group of enterprises.

How to get the service

Responsible Public Authority

Additional information about the service

Sanctions

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.

Fines for non-fulfillment of certain obligations arising from the on Act No 164/2013 Coll. on International Cooperation in Tax Administration, as amended, are not regulated by this Act, and the provisions of Section 247a paragraph 1 letter a) of the Act No 280/2009 Coll., the Tax Code, as amended, "Fine for a Failure to Fulfil an Obligation of a Non-monetary Nature" are therefore used: 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.

Frequently Asked Questions

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

Communication language

According to Section 76 of Act No 280/2009 Coll., the Tax Code, as amended, the language of proceedings is Czech.

Last checked at 30.04.2024