The Austrian Ministry of Finance recently answered
questions in areas of doubt regarding the procedure of
country-by-country reporting (CbCR).
The CbCR obligations have been imposed in Austria for fiscal
years starting from 1 January 2016. In general, an MNE group has to
provide such a report if the total turnover equalled at least EUR
750 million in the preceding fiscal year. The company obliged to
submit the CbCR is: (i) the top tier company that has its legal
seat in Austria; or (ii) an Austrian company assuming the
obligation on behalf of the foreign top tier company for example if
such company is not bound to furnish a report in its state of
residence. Obviously, the latter constellation will not be
prevalent in structures involving an EU-top tier company, as EU
Member States will have implemented the CbCR and exchange of
information requirements similarly. However, the assumption of
reporting obligations bears special relevance for Austrian entities
forming
