Submit a country-by-country report for a multinational company. Unfortunately this specification of service has not yet been completely translated.

If your company operates on a multinational basis, you must submit a country-by-country report under certain conditions.

The purpose of the country-by-country report is to provide tax authorities with additional information on cross-border business activities. Through the preparation of country-by-country reports for multinational enterprises and their automatic exchange, the tax authorities are to be enabled to examine them better. The country-by-country reports are also called country-by-country reports.

You must submit the country-by-country report to the Federal Central Tax Office (BZSt) electronically via the ELMA mass data interface using the BZSt online portal (BOP).

For the country-by-country report, you must submit:

  • an overview by tax jurisdiction
    • Show how your group's business activities are distributed among the tax jurisdictions in which your group operates through companies or permanent establishments. For this purpose, the overview must show certain business figures, based on the consolidated financial statements of your group, in particular the sales revenues, profits and assets per tax jurisdiction.
  • A listing of certain business figures
    • the sales revenue and other income from business transactions with related companies
    • Sales revenue and other income from business transactions with external companies
    • the total of sales revenues and other income
    • income taxes paid in the fiscal year
    • income taxes paid and accrued in the fiscal year for this fiscal year
    • the profit for the financial year before taxes on income,
    • the shareholders' equity
    • the retained profit
    • the number of employees, and
    • the tangible assets
  • a listing of all business units by tax jurisdiction and their principal business activities
    • You should list the entities and permanent establishments included in the jurisdictional breakdown, indicating their principal activities.
  • additional information, if applicable
    • You should add information that will help you to understand the overview and listing by tax jurisdiction.
  • Forms: no
  • Online procedure possible: yes
  • Written form necessary: yes
  • Personal appearance: no

Related Links

  • BZSt-Online-Portal (BOP)

Preconditions

Reporting enterprises that have to prepare and report a country-by-country report are

  • companies with their registered office or management in Germany
  • that prepare consolidated financial statements or are required to prepare consolidated financial statements in accordance with laws other than tax laws (domestic group parent company) and
  • whose consolidated financial statements include at least one foreign company or a foreign permanent establishment and
  • whose consolidated sales revenues reported in the consolidated financial statements amounted to at least EUR 750 million in the previous fiscal year.

Notes

  • The company's reporting obligation can also be fulfilled by an appointed domestic or foreign subsidiary.
  • The reporting obligation does not apply if the domestic company is controlled by another company and included in its consolidated financial statements.
  • However, if the Federal Central Tax Office (BZSt) has not received a country-specific report from abroad, the domestic subsidiary is obliged to prepare and transmit it. If a domestic group company included in the consolidated financial statements is unable to ensure transmission within the deadline, in particular because it is unable to procure or prepare the country-by-country report, it must notify the BZSt of this within the deadline. In doing so, it must provide all information that it has at its disposal or that it can procure.

Related Links

  • § 138a Abgabenordnung (AO)
  • § 2 Absatz 10 EU-Amtshilfegesetz (EUAHiG)
  • § 7 Absatz 10 und 11 EU-Amtshilfegesetz (EUAHIG)
  • Gesetz zu der Mehrseitigen Vereinbarung vom 27. Januar 2016 zwischen den zuständigen Behörden über den Austausch länderbezogener Berichte (MCAA)

Related Links

  • Informationen zum Verfahren des länderbezogenen Berichts auf der Internetseite des Bundeszentralamts für Steuern
  • Informationen zum BZSt-Online-Portal (BOP) auf der Internetseite ELSTER des Bundeszentralamts für Steuern

You must submit the country-specific report via the electronic mass data interface ELMA using the BZStOnline-Portal (BOP) of the Federal Central Tax Office (BZSt).

  • Compile the required documents.
  • Make the required entries in the format prescribed by the Organisation for Economic Co-operation and Development (OECD).
  • Submit the country-specific report electronically via the ELMA mass data interface using the BOP.
  • In the BOP, you will be informed of the approval or rejection of your report by means of an electronic file.
  • The BZSt forwards the country-by-country report to the relevant Land tax authorities and the participating states concerned.
  • The BZSt forwards the data received from the participating states to the competent Land tax authorities.
  • The competent state tax authorities check your country-by-country report as part of the tax audit.

Responsible for the content
Federal Ministry of Finance (BMF)

Last update or date of publication
08.01.2021