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Article:

Deadlines and to dos with respect to Transfer Pricing to be considered at year-end:

15 December 2017

As of 2016 Austrian entities of Multi-National-Entities (MNEs) with a consolidated revenue above EUR 750m in the previous year have to fulfill notification requirements introduced by the Transfer Pricing Documentation Act. Austrian entities (generally including mere permanent establishments as well) being part of such an MNE have to electronically file a notification form with the competent tax office in Austria by the last day of the respective fiscal year (i.e. until 31 December 2017 in case the fiscal year coincides with the calendar year). This serves as an information outlining which entity of the MNE complies with the filing obligation of the CbCR (Country-by-Country Report). For more detailed information in this respect please refer to the following article: https://www.bdo.at/de-at/publikationen/public-interest-de/public-interest-de/austria-tightens-requirements-regarding-transfer-p

Generally, the ultimate parent company of an MNE files the CbCR. However, under specific circumstances an Austrian entity may be obligated by the tax authorities to file CbCR (surrogate parent entity). Please note that other countries also require similar notifications. Therefore, we recommend determining if such notifications have to be filed abroad as well and whether the Austrian entity possibly has to act as a surrogate parent entity.

How can BDO support you?

  • Determination of potential obligation to act as a surrogate parent entity
  • Preparation and electronic submission of the relevant notification form
  • Evaluation of notification requirements in other relevant countries
  • Support in preparing the CbCR as such

Please keep in mind that apart from the CbCR other Transfer Pricing Documentation requirements may have to considered. MNEs which exceeded a turnover of EUR 50m in two previous years have to have a Master and Local file available at the time of filing the tax returns and forward it to the tax authorities within 30 days upon request. Also in this regard our experts would be happy to support you.