In 2022-2023 the structure of many multinational enterprise (MNE) groups has changed significantly. These changes may relate to the restructuring of MNE groups, as well as changes in the parent company and its jurisdiction.
Meanwhile, in accordance with Chapter 14.4-1 of the Russian Tax Code, MNE groups are still required to file a country-by-country (CbC) report for states (territories) where MNE group members are tax residents.
Given the situation in 2022, when preparing a CbC report it is important to consider the changes that have occurred within the MNE group perimeter, the thresholds for total consolidated group revenue for the preceding fiscal year, as well as the specifics of determining an MNE group in a particular jurisdiction. At the same time, the issues regarding MNE groups are not covered in detail, either by the Russian Tax Code or the Transfer Pricing Guidelines developed by the OECD, and each individual case may require further analysis.
Our experts will analyse each specific situation, prepare the CbC report, and then convert it to an XML format in accordance with the respective requirements of the Russian Tax Code and foreign jurisdictions.
We will be pleased to discuss the details, share our practical experience, and answer any questions you may have.
