Netherlands: Measures on exchanging CbC reports | KPMG | GLOBAL
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Netherlands: Measures on exchanging country-by-country reports

Netherlands: Measures on exchanging CbC reports

The Dutch Lower House on 18 April 2017 passed legislation to implement country-by-country (CbC) reporting. The bill must be passed by the Upper House. Assuming the legislative amendments are enacted, they would be effective for reporting of fiscal years commencing on or after 1 January 2016.


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The legislation includes measures:

  • Allowing a group entity to serve as the reporting entity and a designated Dutch group entity to file an incomplete CbC report with all the information at its disposal (the “secondary filing mechanism”) 
  • Clarifying that a permanent establishment situated in the Netherlands cannot act as the surrogate parent entity or the designated group entity
  • Increasing the penalty for noncompliance to €820,000

Also, the Cabinet will present a proposal to allow “voluntary filing” or “parent surrogate filing” as part of the 2018 Tax Plan.

Master file and deviating reporting fiscal years

In an April 2017 letter, the Deputy Minister of Finance confirmed that when the reporting fiscal years for the foreign ultimate parent entity and for a Dutch group entity deviate, the reporting fiscal year of the ultimate parent entity can be used for Master file purposes. With regard to the Local file, it will continue to cover the reporting fiscal year to which the Dutch corporate income tax return relates. 


Read an April 2017 report prepared by the KPMG member firm in the Netherlands: Country-by-Country Reporting – Additional rules for exchanging Country-by-Country reports and OECD update

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