Ministerial Order No. 367/2017 of Portugal, published on December 11, 2017, approves the official form and filing instructions for the Country-by-Country Reporting (CbCR) notification obligation, known as “Modelo 54” (Model 54). This form is used by multinational enterprise (MNE) groups to notify the Portuguese tax authorities about the entity responsible for submitting the CbCR, as required under Article 121-A of the Corporate Income Tax Code.

The notification must be filed electronically and applies to tax periods beginning on or after January 1, 2016. The main goal is to ensure compliance with international tax transparency standards by requiring MNEs to disclose financial and tax-related information on a country-by-country basis.

The purpose of Ministerial Order No. 367/2017 of Portugal is to establish the official form and filing instructions for the Country-by-Country Reporting (CbCR) notification obligation. This order requires Portuguese entities that are part of multinational enterprise (MNE) groups to electronically notify the Portuguese tax authorities about which group entity will be responsible for filing the CbCR report. The notification must be submitted annually, within five months after the end of the relevant fiscal period, to ensure compliance with international tax transparency requirements introduced by Article 121-A of the Corporate Income Tax Code.

Ministerial Order No. 367/2017 primarily targets multinational enterprise (MNE) groups and their obligations regarding Country-by-Country Reporting (CbCR). It does not directly impact small and medium-sized enterprises (SMEs), as these reporting requirements generally apply only to large multinational groups that meet specific revenue thresholds. SMEs that do not belong to such groups are not subject to the notification or reporting obligations established by this order. Therefore, for the vast majority of SMEs in Portugal, Ministerial Order No. 367/2017 has no practical effect.