Country-by-country reporting (cbcr)

A new Ministerial Decree, applicable to FY2016, implemented in Italy the OECD Action 13 recommendations (CbCR obligations) and requires Italian Ultimate Parent Entity to comply with the CbCR obligations if the group has over € 750 million consolidated revenue.

Also Italian subsidiaries could be required to fulfill in the case (i) the Ultimate Parent Entity is resident in a country that has not implemented CbCR rules or (ii) does not have an agreement with Italy or (iii) does not exchange information gathered under the CbCR rules. In this case, the Italian subsidiary must inform the Italian tax authorities and comply with the report (with financial information about profit, taxes, information about the activity etc.) within the deadline for filing its annual corporate tax return (September 30^th 2017).

If the group has got subsidiaries in different EU countries, for CbCR obligations it can fulfill in one country for all EU entities, informing the Italian tax authorities about the choice.

The penalties for failure to comply with the new rules are from EUR 10,000 to EUR 50,000.

If you are in one of the above-mentioned cases and you need our support, please do not hesitate to contact LTA.