By order of the Federal Tax Service dated October 30, 2024 No. ED-7-17/915@ (registered with the Ministry of Justice of the Russian Federation on December 20, 2024), the list of foreign countries with which automatic exchange of country-specific reports is carried out was updated.
Almost all countries that are members of the European Union were excluded from the list of countries with which automatic exchange of country-specific reports is carried out. At the same time, Albania, Cameroon, the Dominican Republic, Mauritania, Papua New Guinea, the territories of Montserrat and the Faroe Islands were included in the updated list.
The EU countries, as well as Australia and Japan, have been systematically failing to fulfill their obligations to automatically exchange country-specific reports since 2022.
The country-by-country report contains information on income, expenses, profit or loss, key indicators characterizing the activities of participants, as well as the amounts of taxes calculated and paid to the national budget system and to the budget of a foreign state. Such information must be provided by the largest international groups of companies whose consolidated revenue for the financial year exceeds 750 million euros.
The country-by-country report is submitted by the parent company of an international group of companies to the tax authority of the state (territory) of which it is a tax resident. In turn, the tax authority of this state (territory) must exchange such reports with the tax authorities of other states (territories) in which other participants of such a group are located.
If the relevant state (territory) of which the parent company of the international group of companies is a resident does not provide the corresponding country-by-country report, the Federal Tax Service of the Russian Federation independently sends the taxpayer a request to provide such a report.
The law firm "Nadmitov, Ivanov and Partners" provides tax support services for the current activities of Russian and foreign companies, protection of the interests of taxpayers, and also consults on issues of international tax planning and regulation of taxation of controlled foreign companies.
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