Preparation of notifications on participation in an MNE Group in accordance with BEPS13

Who should submit a notification on participation in an MNE Group?

  

In accordance with article 105.16-2 of the RTC, taxpayers that are constituent entities of an MNE Group (MNE Group) are obliged to submit a notification on participation in an MNE Group to the tax authorities.

A notification on participation in an MNE Group may be submitted separately by each Russian taxpayer that is a member of an MNE Group or by a surrogate entity of the MNE Group in Russia that will submit a notification to the tax authorities with an indication of all Russian taxpayers of the MNE Group.

A notification on participation in an MNE Group is submitted according to the format established by the tax authorities in the Russian language in the electronic form. The content of a notification on participation in an MNE Group is regulated by the provisions of paragraph 5 of article 105.16-2 of the RTC.

Since 2017, the submission of notifications on participation in an MNE Group is mandatory.

The deadline for submitting a notification on participation in an MNE Group is no later than 8 months from the date the MNE ultimate parent entity’s reporting period ends.

The Russian legislation provides for an exemption from submitting a notification of participation in an MNE Group if the ultimate parent company, surrogate entity or constituent entity of an MNE Group that is a resident of the FR has submitted a notification indicating the taxpayer.

Failure to submit a notification on participation in an MNE Group or submission of incorrect information will result in a fine of RUB 50,000. 

Our services

  

  • Turnkey preparation of notifications on participation in an MNE Group according to the requirements of the RTC.
  • Coordination of the process of preparing and submitting notifications in all tax jurisdictions of the MNE Group’s presence. 

Team

  

Since 2017, KPMG has an experienced team of professionals specializing in the preparation of CbCRs and the preparation of notifications on participation in MNE Groups in accordance with BEPS13 requirements based on the developed IT solution KPMG BEPS Automation Tool. Since 2017, KPMG specialists have successfully prepared more than 159 notifications of participation in an MNE Group.