The Dutch State Secretary of Finance declared an extension of the filing period for entities of multinational groups (with a consolidated group revenues of at least EUR 750 million) to 1 September 2017 regarding the following notifications:
- whether or not these entities are a so-called ‘reporting entity’ under the Dutch Country-by-Country reporting legislation, and;
- which group entity is the reporting entity.
In addition, a special digital application has been developed by the Dutch tax authorities for notifying the identity of the reporting entity. The State Secretary of Finance announced coming with a proposal to obligate the use of the digital notification tool and with a proposal to allow voluntary filing by the ultimate parent entity.
The extension of the notification deadline is caused by the fact that the required international agreements necessary to exchange the Country-by-Country reports are not yet in place. The Multilateral Competent Authority Agreement (MCAA) has so far been signed by 49 countries, but these countries still have to indicate with which countries they will effectively exchange Country-by-Country reports. Only in case of a “match” countries will effectively exchange the reports. The State Secretary of Finance indicates that by July 2017 it should be known which countries have appointed each other to exchange Country-by-Country reports.
For further information on Country-by-Country developments worldwide, see http://newslink.loyensloeff.com/l/02f820d6affa4bceabc43bb5707e71ef/2FD36EA2/F03F45D6/112016.
The text of the above mentioned decree is available here.
Compliments of Loyens & Loeff – a member of the EACCNY