The Country-by-Country Report will be made public
The so-called Country-by-Country Report (“CbCR” or “Report”) is one component of the transfer pricing documentation obligation.
In the Czech Republic, the obligation to compile the CbCR was implemented in 2017 (for the period starting in 2016) and until now it has been the only mandatory document of the Master file, Local file and CbCR triad. The obligation to compile the CbCR applies only to multinational groups whose turnover exceeds the EUR 750M threshold. . The report itself does not contain financial data on individual companies in the group, but shows the distribution of selected cumulative financial indicators among the individual jurisdictions. A list of the companies in the group, including the functions held, is part of the report. Currently, the reported data are only available to the tax administrations of the countries concerned.
At the European Union level, a directive introducing a CbCR disclosure obligation passed through the approval process during autumn. The directive came into force on 21. 12. 2021 and member states should implement it in their local legislation within 18 months. Following the deadlines set, the first public reporting period should start no later than 22. 6. 2024. The deadline for compiling the public report is the same as for the conventional CbCR, i.e. 12 months after the end of the accounting period.
The specific terms of the public CbCR will be known after implementation in the Czech legislation.