Brief Information: Notification requirement for the Country-by-Country Report until 31.12.2016

The new Transfer Pricing Documentation Act (VPDG) sees, besides the creation or provision of Master file and Local file for particularly large corporations (consolidated group revenue from the previous year of at least£750 millionio. €) the obligation to prepare the Country-by-Country Reports (CbC-Report) again. Although the submission of the CbC-Report is generally the Group parent company concerns, Austrian companies that are part of such a large group are affected by a Notification requirement affected. Namely, you must, according to § 4 VPDG, by 31.12.2016 report, whichforeignparent company will prepare the CbC report. The CbC report should be made between the Financial administrations the countries relevant to the group Exchanged and contains additional information intended to help national tax authorities select companies for audit. The BMF has now released the form „VPDG 1 - Country-by-Country Reporting Notification under Section 4 of the German Transfer Pricing Documentation Act (VPDG)“Published. It is important that each Austrian society, which is part of such a multinational group, must comply with this reporting obligation. Even if the revenue threshold of €50 million has not been exceeded and therefore there is no obligation to prepare standardised transfer pricing documentation (e.g. Austrian Local File).

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