Country-by-Country reporting notification 2019
With this announcement we would like to gently remind you the Country-by-Country (CbC) reporting notification requirements (FY 2019) in the Netherlands.
Multinational Groups with an annual consolidated group revenue of EUR 750 million or more in the preceding fiscal year have to prepare and file a CbC report. In case the CbC report is to be filed in the Netherlands, the reporting entity is required to submit the report to the Dutch Tax Authorities within 12 months after the reporting year of the ultimate parent company.
Each Dutch entity (company and permanent establishment) of such a group has to notify the Dutch Tax Authorities of the identity and tax residency of the group entity that will submit the CbC report of the group that respective fiscal year.
Penalties for non-compliance with CbC requirements
The penalties for intentionally or due to gross negligence not (fully) complying with the CbC requirements in the Netherlands can result in fines of up to EUR 830,000 per entity and criminal prosecution. In addition, any non-compliance with the transfer pricing documentation requirements in general (Local File, Master File and CbC report) can lead to a reversal of the burden of proof and may affect the personal liability of directors.
The notification for CbC reporting in the Netherlands should be filed via the notification portal of the Dutch Tax Authorities by a representative of the group itself or an external advisor like ABAB International. This notification should be filed on or before the last day of the reporting year of the group. In case the group has a reporting year that ended after 31 December 2019, the notification has to be filed with the Dutch Tax Authorities on 31 December 2019 at the latest. The web portal allows authorized group entities to file a CbC notification for all the entities and branches located in the Netherlands.
We would be happy to assist you with the notification for fiscal year 2019 and any other queries you may have in the area of transfer pricing. Should you have any questions, please do not hesitate to get in touch with our experts.