Corporate Income Tax Law amendments gazetted in the Official Journal 1932/2015 regarding transfer pricing (TP) reporting obligations in line with Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project came into effect on 1 January 2017.
The country by country (CbC) reporting requirements are applicable to taxpayers that are part of a multinational corporate group deriving consolidated annual income of at least EUR 750 million. When determining the obligation to submit the CbC report for the first reporting year the consolidated revenue generated by the group during the current (not the previous) financial year should be taken into consideration. To be subject to the CbC reporting requirement groups need to consist of at least two entities domiciled in different jurisdictions or an entity domiciled in one jurisdiction but operating through a permanent establishment located in another country or territory.
