Information Country-by-Country reporting
As of 1 January 2016, MNE groups having a total consolidated group revenue equal to or exceeding EUR 750 million in the fiscal year immediately preceding the Reporting Fiscal Year covered by the CbC-report, have to provide tax administrations on an annual basis with information about their profits, income taxes paid and activities. A template developed by the OECD is used for this reporting obligation.
Other locations where relevant information can be found are:
Logius, the digital government service of the Ministry of the Interior and Kingdom Relations, provides The netherlands Tax Authorities with the Electronic Messaging (EM) service, through the portal ‘Digipoort’.
The notifications following article 29d, paragraph 1 and 2 CITA must be filed here. This website also includes additional information regarding the notification.
On the basis of the CITA, Reporting Entities of MNE Groups that are tax resident in The Netherlands are required to provide information to the tax inspector on their own initiative. This has been stipulated in Chapter VIIa (“Additional transfer pricing documentation obligations”) of the CITA, in articles 29b-29h, excluding article 29g10.
With this new obligation to file a CbC-report, The Netherlands implemented the outcomes of Action 13 of the OECD’s Base Erosion and Profit Shifting project (BEPS-Project) for fiscal years beginning on or after 1 January 2016. The new standard has been published in ‘Transfer Pricing Documentation and Country-by Country Reporting Action 1311’ (October 5 2015) and are included in the OECD’s Transfer Pricing Guidelines as the new chapter 5.
An MNE Group having total consolidated group revenue of more than EUR 750 million in the Fiscal Year immediately preceding the Reporting Fiscal Year has to prepare an annual CbC-report.