CbCR Report for the tax year of 2020 needs to be submitted by the end of the next tax year within 12 calendar months i.e., 31 December 2021.
The report needs to be submitted by (i) the group parent company/authorised entity; or (ii) if any of the below conditions are met by the Azerbaijani tax resident entity of the group:
- If the group parent company/authorized entity does not bear CbCR reporting liability as per laws of the country of their residence;
- If it is operating in the Republic of Azerbaijan and having a total income of more than 750 million euros in the financial year (the same as tax/calendar year);
- If by the end of the reporting year there is no CbCR report exchange agreement between the Azerbaijani tax authorities and tax authorities of the country of residence of the group parent company/authorized entity;
- If the Azerbaijani tax authorities notify the Azerbaijani tax resident that according to notification of the foreign tax authorities, the group parent company/authorized entity did not file the CbCR report.]
Should the CbCR report be filed by the authorized entity of the group by the end of the tax year and the following conditions are met, filing CbCR report by the Azerbaijani tax resident entity of the group will not be necessary:
- If CbCR report filing is required by country of residence of the authorized entity;
- If there is respective agreement between tax authorities of Azerbaijan and tax authorities of the country of resident of the authorized entity;
- If the tax authorities of the country of residence of the authorized entity notify Azerbaijani tax authorities that no CbCR report was filed by the authorized entity;
- If by 30 June entity files to Azerbaijani tax authorities the CbCR notification.
In case the CbCR report to the tax authorities is filed by the end of this year, i.e. 31 December 2021, other than in case of specific request from the tax office, this requirement would depend on the following factors:
- Whether there the group parent company/authorised entity files such report back in the respective country of residence;
- Whether there is a respective exchange agreement between Azerbaijan and the country of residence of the group parent company/authorised entity.
KPMG Azerbaijan will be pleased to support you with determining whether above reporting conditions are met by your company. And if yes, we will also assist you with compilation and preparation of the needed data required for CbCR report.