ANNEX I
Common template for the report on income tax information
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REPORT ON CORPORATE INCOME TAX INFORMATION in compliance with chapter 10a of Directive 2013/34/EU (‘country-by-country reporting’) |
General reporting instructions
Information required by Article 48c of Directive 2013/34/EU shall be visually presented in accordance with the specifications provided in this template. Additional information may be disclosed in the report, whether in the form of text, images or other means.
Section 1
General information
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Name of the ultimate parent of the group / of the standalone undertaking |
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Country where the ultimate parent has its registered office |
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Financial Year – start date |
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Financial Year – end date |
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Reporting currency |
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Is the information in the report based on reporting instructions used for tax purposes, pursuant to Section III, Parts B and C, of Annex III to Directive 2011/16/EU (yes/no)? |
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Specific reporting instructions for Section 1
The name of the ultimate parent of the group / of the standalone undertaking shall correspond to the name provided in the statutes or instruments of incorporation of the undertaking to which the report on income tax information relates.
Whether the reporting instructions pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU have been used as a basis to draw up the report, pursuant to Article 48c(3) of Directive 2013/34/EU, this shall be indicated. In the template this would be done by stating ‘yes’ or ‘no’ in the appropriate box. In the case where a reporting undertaking chooses to apply those instructions, these shall apply consistently to Section 2 and 3. These reporting instructions take into account the OECD standards in relation to action 13 of its Action Plan on Base Erosion and Profit Shifting (BEPS).
Section 2
Overview of information on a country-by-country basis
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Tax jurisdiction |
Country code |
Revenues |
Profit (loss) before income tax |
Income tax paid – on cash basis |
Income tax accrued – current year |
Accumulated earnings |
Number of employees |
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All other tax jurisdictions (aggregated basis) |
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Specific reporting instructions for Section 2
In the table, a given line shall correspond to a given Member State or to a given tax jurisdiction, including a country in the European Economic Area other than a Member State of the European Union, as mandated by the applicable national law.
As many additional columns may be added as necessary on the right-hand side of the table, for any additional information a reporting undertaking may disclose.
The information required by the third subparagraph of Article 48c(5) of Directive 2013/34/EU shall be presented in the line with the heading ‘All other tax jurisdictions (aggregated basis)’. The information shall be disclosed as a zero figure or ‘nil’ if the jurisdictions disclosed line by line cover all the activities of the reporting standalone undertaking or ultimate parent undertaking.
Amounts shall be reported down to the unit with no scaling applied, and with an accuracy deemed appropriate by the reporting undertaking. For example, revenues of EUR 1 234 567,89 would be reported as EUR 1 234 568 (down to the unit, no scaling). With an accuracy to the nearest EUR 1 000, the amount would be reported as EUR 1 235 000.
Case where the report is not based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Directive 2011/16/EU:
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Revenues in a jurisdiction shall be reported with positive amounts. Conversely, where there are overall negative revenues in that jurisdiction, these shall be reported with negative amounts. |
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Profit before income tax in a jurisdiction shall be reported with positive amounts. Conversely, where there are overall losses before tax in that jurisdiction, these shall be reported with negative amounts. |
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Income tax paid on cash basis in a jurisdiction shall be reported with positive amounts. Conversely, where there is an overall net refund of income tax in that jurisdiction, or where refunds of income tax exceeded payments of income tax in the same financial year, income tax paid (on cash basis) shall be reported with negative amounts. |
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Income tax accrued – during the course of the current year in a jurisdiction shall be reported with positive amounts where this corresponds to an overall accrued tax expense in that jurisdiction. Conversely, where there is an overall accrued tax credit in that jurisdiction, the amounts shall be reported with negative amounts. |
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Accumulated earnings in a jurisdiction shall be reported with positive amounts where there are net accumulated profits overall in that jurisdiction. Conversely, where there are overall net accumulated losses in a jurisdiction, accumulated earnings shall be reported with negative amounts. |
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The number of employees in a jurisdiction shall be reported with positive amounts. Decimals may be shown as deemed appropriate by the reporting standalone undertaking or ultimate parent undertaking. |
Case where the report is based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU:
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Information relating to undertakings deemed not to be resident in any tax jurisdiction for tax purposes shall be included in the line ‘All other tax jurisdictions (aggregated basis)’. |
Section 3
List of subsidiaries and activities
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Member State or tax jurisdiction |
Country code |
Name of each subsidiary undertaking in the Member State or tax jurisdiction |
Brief description of the nature of activities in the Member State or tax jurisdiction |
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Subsidiary a Subsidiary b Subsidiary c .... |
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Subsidiary d Subsidiary e Subsidiary f .... |
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Specific reporting instructions for Section 3
The lines in the table shall correspond to the lines disclosed in Section 2 per Member State or tax jurisdictions. However, the table for Section 3 need not include the line ‘All other tax jurisdictions (aggregated basis)’.
The name of the subsidiary undertakings in the Member State or tax jurisdiction shall be disclosed for each subsidiary undertaking consolidated in the financial statements of the ultimate parent undertaking in respect of the relevant financial year, and presented in the line corresponding to the Member State or tax jurisdictions in which that subsidiary is established. Establishments, fixed places of business or permanent business activities other than those operating via a subsidiary undertaking need not be disclosed.
Case where the report is not based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU:
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The ‘Brief description of the nature of activities in the Member State or tax jurisdiction’ shall be drawn up on the basis of Annex I of Regulation (EC) No 1893/2006 of the European Parliament and of the Council (1) establishing the statistical classification of economic activities (NACE), taking account of the activities of the group or standalone company in the country as a whole. For example, taking all the activities in a given country into account, where these cover section C and G of Annex I of Regulation (EC) No 1893/2006, the corresponding text would be: ‘manufacturing / wholesale and retail trade; repair of motor vehicles and motorcycles’. |
Case where the report is based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU:
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The information required by the line entitled ‘Brief description of the nature of activities in the Member State or tax jurisdiction’ shall be disclosed on the basis of the following list of main business activities, taking into account all the activities in a given country:
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For instance: ‘Manufacturing or Production / Sales, Marketing or Distribution’. In the case where the activities are reported as ‘Other’, no further description is required. |
Section 4
Omitted information
Information omitted (if any) for this financial year:
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Information omitted in previous financial years, which is disclosed in this financial year (if any):
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Specific reporting instructions for Section 4
Applicable national law pursuant to Article 48c(6) of Directive 2013/34/EU may provide for the ability to temporarily omit information.
Where information is omitted in either table laid down in section 2 or 3, this shall be disclosed in the first box in Section 4. For each item omitted (if any), the description of such item as well as a duly reasoned explanation regarding the reason for the omission shall be provided in the box.
For information that had been omitted in a previous financial year and which is disclosed in the report on income tax information for the current financial year, the description of each item shall be provided in the second box in Section 4, indicating for each item disclosed the financial year in which the information had been omitted.
Section 5 (non-mandatory)
Explanations for material discrepancies between income tax paid and accrued
Explanations on material discrepancies between amounts of income tax accrued during the relevant financial year and amounts of income tax paid on a cash basis as disclosed in Section 2, where applicable at group level, considering where appropriate corresponding amounts concerning previous financial years:
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Specific reporting instructions for Section 5
Unless provided otherwise by the applicable national law, it is left to the discretion of reporting undertakings whether or not to provide such information. Should no such information be disclosed, this section may be omitted. This section is mentioned in this common template by reference to Article 48c(7) of Directive 2013/34/EU.
(1) Regulation (EC) No 1893/2006 of the European Parliament and of the Council of 20 December 2006 establishing the statistical classification of economic activities NACE Revision 2 and amending Council Regulation (EEC) No 3037/90 as well as certain EC Regulations on specific statistical domains (OJ L 393, 30.12.2006, p. 1, ELI: http://data.europa.eu/eli/reg/2006/1893/oj).