Brazil’s tax authorities issued Normative Instruction 1.681 (29 December 2016) that establishes the rules for mandatory annual filing of country-by-country (CbC) reports. The first CbC report will concern information relating to calendar year 2016.
The CbC report filing is required for entities that, as the ultimate parent company of a multinational group, are residents of Brazil for tax purposes, and that have total consolidated group revenue of the fiscal year prior to the year of the CbC reporting of an amount greater than R$ 2.26 billion if the controller is domiciled in Brazil or €750 (or the equivalent in local currency) if the controller is domiciled abroad.
The CbC report is to be filed along with the taxpayer’s corporate income tax return (ECF) for the related year.
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