As part of continuing efforts to boost transparency by multinational enterprises (MNEs), 31 countries, including the Czech Republic, signed today the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports.
With Country-by-Country reporting tax administrations where a company operates will get aggregate information annually, starting with 2016 accounts, relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group. It will also cover information about which entities do business in a particular jurisdiction and the business activities each entity engages in. The information will be collected by the country of residence of the MNE group, and will then be exchanged through exchange of information supported by such agreements as signed today. First exchanges will start in 2017-2018 on 2016 information. In case information fails to be exchanged, the Action 13 report on transfer pricing documentation provides for alternative filing so that the playing field is levelled.
More information here.
27th March 2020