Serbia’s parliament in December 2019 passed legislation that amends the corporate income tax law, and specifically that includes requirements for country-by-country (CbC) reporting of controlled transactions within a corporate group.
The rules provide that annually, a CbC report must be submitted by the Serbian tax resident that is the ultimate parent legal entity of an international group of related legal entities. The CbC report is due within 12 months after the end of the business year for which the CbC report is being prepared.
For these purposes, an international group of related legal entities is a group of entities that are interconnected by ownership or control in terms of international accounting standards (i.e., IFRS) and that have total consolidated income of at least €750 million annually. In addition, it is necessary that at least one member of the multinational group be required to prepare consolidated financial statements in accordance with IFRS (that is, this member has such an obligation if its shares are traded on a regulated market, and if the group members are subject to taxation in at least two tax jurisdictions (including permanent establishments)).
The “ultimate parent” entity of an international group is a legal entity that is a member of an international group, that has the ownership or control of one or more legal entities, that has an obligation to prepare consolidated financial statements (or that would be required to do so if it traded shares on a regulated market). And there is no other legal entity within the international group that has ownership or control of that entity and that is required to prepare consolidated financial statements.
A separate rulebook (that is, regulation) will be expected to specify in greater detail the conditions and manner of submission of the CbC report.
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