As regulated by the Councile Directive (EU) 2016/881 the Country-by-Country Report (hereinafter: the CbCR) is a report by which a group of multinational enterprises (MNEs)
discloses annual information about the group by every tax jurisdiction in which the MNE group does business. Ultimate parent entities of the MNEs group are required to file the CbCR (under
exceptional circumstances, surrogate parent entities and constituent entity) if the group amounted total consolidated corporate revenue over 750 million EUR in the year that precedes
the year for which the CbCR is being filed.
Notifications on the status of each constituent entity – deadline 30th April 2017
Each constituent entity of the group of MNEs is required to submit a notification on its status within the MNEs group, i.e. information whether it is obligated to file the CbCR for the group, and if
it is not obligated to do so, it is required to provide information about the company that is obligated to file the CbCR for the group. In Croatia this applies to companies that are tax residents in
Croatia and are a part of the MNE group, and to branches of a foreign company which are a part of the MNE group. Deadline for first submission of the notification is 30th April 2017, i.e. 30th April
of every year to follow (if it concerns a taxpayer whose tax year matches a calendar year).
Information provided by the CbCR
The CbCR is an integral part of the Croatian Ordinance on Automatic Exchange of Information in the Field of Taxation, and provides information on the amount of corporate revenue, profits and losses before taxes, accounted and paid corporation tax, capital, number of employees and tangible assets, as well as the economic activity and information about each constituent entity of the MNE group.
Deadline for filing the CbCR
Deadline for filing the CbCR is 12 months after the end of the tax year that starts on 1st January 2016 and later. Exceptionally, if entities obligated to submit the CbCR are constituent entities
which are not the ultimate parent company or a surrogate parent company, the deadline is set forward to 12 months after the end of the year that starts on 1st January 2017 and later. For
a misdemeanor of failing to submit the CbCR a fine can be imposed in a range between HRK 2.000,00 and 200.000,00 for reporting entity and in a range between 2.000,00 and 20.000,00 kn for a
responsible person of the reporting entity. Given that the first reporting obligations are due by the end of April, all entities that are a part of a multinational group should determine
whether they are addressed by any of the abovementioned requirements.