Transfer pricing - news

Country-by-country reporting (“CbCR”) is one of the cornerstones of the three-tier approach to transfer pricing reporting and is prescribed by the OECD BEPS Action Plan. The CbCR is filed by the ultimate parent of those multinational groups (“MNG”) that have total consolidated revenues of EUR 750 million or more in the last financial year. The CbCR is filed for the periods from 2016 onwards.

The Croatian Tax Authorities have published a notification to taxpayers that are members of MNGs subject to CbCR reporting to notify the Tax Authorities’ Head Office about their membership.

The deadline for notifying the Tax Authorities is at latest four months after the end of the corporate tax assessment period (e.g. by 30 April 2017 if the tax assessment period ends on 31 December 2016).

The Croatian MNG members are to provide the notice to the Tax Authorities as follows:

1. Each Croatian tax-resident MNG member should notify the Tax Authorities on whether the ultimate parent, the substitute parent, or a constituting member of the MNC is the CbCR filing entity on behalf of the MNG it belongs to.
2. Each Croatian tax-resident MNG member that is not the ultimate parent, the substitute parent, or the constituting member defined in line with sections 102, 103 and 104 of the Automatic Tax Data Exchange Regulations is to notify the Tax Authorities on the name and country of tax residence of the entity that will file the CbCR report on behalf of the MNG it belongs to. 

The notices from points 1. and 2. above are delivered by post to the Ministry of Finance, Tax Authorities, Head Office, Normative Activities and International Cooperation Department, Boškovićeva 5, 10000 Zagreb.

The ultimate parent, the substitute parent, or the constituting member are required to deliver the first CbCR for the tax year starting on 1 January 2016 or later within 12 months from the last day of the reporting period.

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