Accueil Transfer Pricing

Country by Country Reporting: Notification obligation before December 31, 2016

In the context of the implementation of the Country by Country reporting, the OCDE offered the option for countries to introduce provisions requiring a notification from the local constituent entities which allows the tax authority to identify the group’s reporting entity.

As of December 16, the countries for which the first notification should be made on or before December 31, 2016 (for MNE groups with a reporting period ending on December 31, 2016) are the following:

 

Austria Form “VPDG 1” available on the website tax authorities. The form can be sent to the com-petent tax office in a similar way other official documents are sent to the responsible tax office
Bulgaria Not yet announced
Denmark Form 05.034 available on the website tax authorities. The form can be sent to the compe-tent tax office in a similar way other official documents are sent to the responsible tax of-fice.
Spain Notifcation through
Ireland Notification will be made via Irish Revenue’s online tax portal – Revenue Online Service (ROS).
Luxembourg Electronic filing expected.

 

Even though some of these jurisdictions have not finalized the procedures for providing this notification to the local tax authority, a notification before December 31, 2016 should be made to avoid any potential penalties.

  • Grégoire de Vogüé

    Grégoire de Vogüé, Partner, heads the Transfer Pricing team. He has acquired more than 20 years in all transfer pricing…

  • Eric Lesprit

    Eric has more than 25 years’ experience in transfer pricing and international tax. He held various senior positions at the…

  • Gianmarco Monsellato

    Gianmarco Monsellato, French tax attorney, was the CEO of Deloitte Société d’Avocats from 2004 to 2016. Now CEO of Deloitte…

  • Aymeric Nouaille-Degorce

    Aymeric Nouaille-Degorce, Partner, is a member of the Transfer Pricing’s team. He has more than 22 years of experience in…

  • Julien Pellefigue

    Julien Pellefigue, Partner, is an Economist in the Transfer Pricing department of Deloitte Société d’Avocats. He has more than 13…