TAX ALERT October 2017 – CbCR

We would like to inform you that on 19 September 2017, an amendment of the Law on International Cooperation in Tax Administration has come into force. The law introduces the so-called Country-by-Country Reporting (CbCR) obligation the purpose of which is to ensure automatic international exchange of information.

The reporting obligation applies to multinational groups with annual consolidated sales exceeding EUR 750m. The reporting is performed on behalf of the whole group by the ultimate parent company (or by a surrogate parent company) to the locally competent tax authority in the format and structure prescribed by the tax administration of the country where the ultimate parent company (or a surrogate company) is resident.

The Czech subsidiaries of the qualifying multinational groups will be obliged to provide the relevant information to the ultimate parent company (or to a surrogate company) so that the latter can fulfill its obligation in the country where it is resident and also to file the so-called Notification (Ohlášení in Czech) until 31 October 2017. The Notification is filed with the Specialised financial authority and serves to identify the ultimate parent company of the group and inform the tax authorities about the company that will perform the filing on behalf of the group. If there is a change in any of the information being notified, a new Notification has to be filed within 15 days from the date when the change occurred.

The Notification is filed through the digital filing platform of the Czech tax administration (EPO) and is available via the following link: 

If the Czech company is the ultimate parent company (or a surrogate company), it will be obliged to file a different form (Oznámení in Czech) with the Specialised tax authority. The form will be published on the server of the Czech tax administration. Based on information in the media, there will be around 10-15 Czech multinational groups qualifying for this obligation.

If you need further information, please contact us at any time.