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Assistance in country-by-country reporting: CBCR declaration and CByR notification

We assist you in your Country by Country declarations and notifications (CBCR). This initiative by the OECD is taken up by European Directive (EU) 2016/881 of the Council of 25 May 2016 amending Directive 2011/16 / EU as regards the automatic and compulsory exchange of information in the tax field.
In Luxembourg, the directive was transposed into law on December 23, 2016.

We support you in your CBCR obligations

The CBCR declaration

We support you in:● defining the scope of your obligations● collecting information for the reporting entity● setting up a data collection tool for entities in the group of companies● review of the information communicated● preparation of the declaration and annexes● filing the declaration with the tax authorities

CBCR notification

We support you in:● collecting information from the reporting entity● review of the information communicated● preparing the notification● filing the notification with the tax authorities

What are your legal obligations regarding CBCR reporting?

Which companies are affected by the country-by-country declaration?

Multinational enterprise groups with consolidated turnover of more than 750,000,000 euros (750 million) are required to file a country-by-country report.
The group entity responsible for this declaration is either the ultimate parent entity of the multinational enterprise group which resides for tax purposes in the Grand Duchy of Luxembourg, or an entity which has been declared as a reporting entity to the tax authorities.

All other entities, resident for tax purposes in Luxembourg, of the group subject to country-by-country reporting obligations must file a country-by-country reporting notification in Luxembourg.

Which countries are affected by the country-by-country declaration?

The countries concerned are:● for the Fiscal Year beginning on or after January 1, 2016: South Africa, Germany, Australia, Austria, Belgium, Brazil, Bulgaria, Canada, Colombia, Cyprus, Korea, Croatia, Denmark, Spain, Estonia, United States of America, Finland, France, Gibraltar, Greece, Guernsey, Hungary, Isle of Man, India, Indonesia, Ireland, Italy, Japan, Jersey, Latvia, Liechtenstein, Lithuania, Malaysia, Malta, Mexico, Norway, New Zealand, Netherlands, Pakistan, Poland, Portugal, Slovak Republic, Czech Republic, Romania, Russia, United Kingdom, Singapore, Slovenia, Sweden, Switzerland.● for the Fiscal Year beginning on or after January 1, 2017: the previous courts, Argentina, Chile, China, Iceland, Uruguay.● for the Fiscal Year beginning on or after January 1, 2018: the previous courts, Andorra, Monaco.● for the Fiscal Year beginning on or after July 1, 2018: the previous courts, Mauritius.● for the Fiscal Year beginning on or after January 1, 2019: the preceding jurisdictions, Hong Kong.

What is the competent administration in Luxembourg?

These companies are required to file the country-by-country declaration with the Direct Tax Administration (ACD).

What are the deadlines for making the declaration?

These companies are required to file the group's country-by-country declaration annually.
This declaration must be filed within twelve months after the last day of the reportable fiscal year.

How can we assist you?

Our firm is involved in defining the data to be collected according to BEPS regulations and European regulations as well as Luxembourg rules. We also assist groups in the collection and processing of data from all entities and the preparation of the country-by-country declaration.

What are your legal obligations regarding CBCR notification?

Which companies are affected by the country-by-country notification?

All entities, resident for tax purposes in Luxembourg, of a group subject to CBCR reporting obligations and which do not make country-by-country reporting must file a country-by-country reporting notification in Luxembourg.

Which administration is competent in Luxembourg for this notification?

These companies are required to file the country-by-country notification with the Direct Tax Administration (ACD).

What are the deadlines for notification?

These companies are required to file the group's country-by-country declaration annually.This declaration must be filed no later than the last day of the multinational group of companies' reportable fiscal year.

How can we assist you?

Our firm is involved in the preparation of the country-by-country notification for the Luxembourg companies concerned.