Bundeszentralamt für Steuern CbCR Guidance (Germany)

Here is a concise summary of the key details on completing and filing the Country-by-Country (CbC) report in Germany:

Completing the CbC Report

  • The CbC report must include the following information for each tax jurisdiction where the multinational enterprise (MNE) group operates:
    • Sales and other income from transactions with affiliated and unaffiliated businesses
    • Total sales and income
    • Profit (loss) before tax
    • Income tax paid and accrued
    • Number of employees
    • Tangible assets
    • A list of the key business activities of each constituent entity 
  • Amounts should be reported in full units without decimals, and negative values should be indicated with a “-” 
  • The report must be provided in the format of the OECD’s standardized XML Schema 
  • The language used should preferably be English, if permissible under local law 

Filing the CbC Report

  • The CbC report must be filed with the German Federal Central Tax Office (BZSt) no later than one year after the end of the fiscal year it covers 
  • The report must be filed electronically through the ELMA data transmission system 
  • The BZSt will conduct a two-stage check of the submitted report – first the ELMA entrance test, then the technical procedure check. Only after passing both checks will the report be considered successfully filed 
  • The BZSt is required to store the CbC reports for 15 years 
  • Businesses subject to the CbC reporting requirement do not need to inform the BZSt in advance about which group company will submit the report.

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