On Monday November 21, 2016, the Dutch State Secretary of Finance announced he is postponing the deadline for the country-by-country-reporting notification.
The first CbC-reports, covering FY2016, are not due until the end of 2017. However, Dutch CbCR regulations require all Dutch entities that fall under the scope of CbCR to proactively disclose to the Dutch tax authorities the details of the Dutch or foreign group entity that will file the CbC-report on behalf of their group. In principle, this CbCR notification needs to be done before the end of the fiscal year to which the CbC-report pertains.
For FY2016 however, it has now been decided to postpone the CbCR notification deadline from December 31, 2016 (or the end of the fiscal year) to August 31, 2017.
The CbCR notification is one of the requirements for so-called 'surrogate filing', which enables multinational groups to file a CbC-report in just one country, instead of in all the countries where they have entities subject to local CbCR rules. Since it is currently still not clear which countries will have implemented CbCR in time for FY2016 (including signing the necessary exchange of information agreements), it is difficult for multinational groups to decide in which country they will file their CbC-report for 2016. This is the reason that the CbCR notification deadline has been postponed.
In the same decision, the State Secretary of Finance announced that he will soon issue guidance on the Dutch tax authorities' online CbCR notification tool and on voluntary CbCR filing.
Under CbCR rules that have been enacted into Dutch tax law starting FY2016, Dutch members of multinational groups with consolidated revenues exceeding EUR 750 million are required to annually file a comprehensive CbCR-report, containing detailed information relating to the global allocation of the group’s income and taxes paid together with indicators of the location of economic activity within the MNE group.