Frequently Asked Questions

This FAQ is strictly for informative purposes. The legal provisions and lower tier legislation are explicitly take precedent.

As of 1 January 2016, MNE groups with an annual consolidated group revenue equal to or exceeding EUR 750 million have to provide – on an annual basis – tax administrations with information about e.g. their profits, income taxes paid and activities. A template developed by the OECD will be used for this reporting obligation (the CbC report).

Constituent Entities which are resident for tax purposes in the Netherlands that are part of an MNE Group to which the CbC-reporting legislation is applicable, are required to provide a yearly notification via the CbC notification portal which of the entities within the group is the Reporting Entity.

This notification is obligatory for all Constituent Entities resident in the Netherlands. For practical purposes it is allowed that one Constituent Entity notifies on behalf of itself and all other Constituent Entities within the MNE group which are resident in the Netherlands.

The Dutch Tax Authorities need to be notified ultimately on the last day of each Reporting Year (i.e. the year which you are reporting on).

Information and background on CbC and how to file the CbC report with the Dutch Tax Authorities can be found at the site 'Ondersteuning Digitaal Berichtenverkeer': https://odb.belastingdienst.nl/

If you file a new notification via the notification portal we will use the last notification filed.

Multinationals who file the CBC report in the Netherlands must use the Digipoort service provided by Logius. Refer to www.logius.nl. For normal reporting years the deadline is the 31st of december, in case of divergent reporting years the deadline is the end of the reporting period plus 12 months.

When you filled in all the relevant information on the notification portal, you still have to validate the notification to complete it. You will receive an e-mail with a link to validate the information given. After validation you receive an e-mail with the details you filled in on the notification portal.

If the list of group entities was succesfully send to us, the remark 'Group entityfile included' will appear in the e-mail containing the summary of your notification.

You need to fill in the name of the Constituent Entity resident in the Netherlands notifying the Dutch tax Authorities on behalf of itself and all other Constituent Entities within the MNE group which are resident in the Netherlands.

The Tax Identification Number (‘TIN’) equals the ‘RSIN’ by which the notifying Constituent Entity is registered with the Dutch Tax Authorities (the RSIN registration number can be found at the Dutch Chamber of Commerce website: www.kvk.nl). If the RSIN number has less than 9 digits prefix zero’s need to be added. Do not use spaces or points.

Fill in the registered address for the Constituent Entity resident in the Netherlands notifying the Dutch tax Authorities.

The house number for the registered address, excluding extensions.

Any extensions to the address.

This is the zip code / postal code relating to the address (without any spaces).

Fill in the city relating to the address for the Constituent Entity resident in the Netherlands notifying the Dutch tax Authorities.

The Reporting year is the yearly reporting period used by the ultimate parent company to draw up its financial accounts. Fill in the beginning and end date (including that day) using the format ‘dd-mm-yyyy’.

Fill in whether the entity is representing itself or whether it is represented by an endorsee (a representative).

If you choose to make use of an endorsee / representative you need to fill in its company name.

If you choose to make use of an endorsee / representative you need to fill in its Beconnummer. A Beconnummer is a number used by representatives which have registered themselves with the Dutch tax authorities.

Fill in the sex of the endorsee.

Fill in the first name of the endorsee.

Fill in any preposition contained in the name.

Fill in the surname of the endorsee.

Fill in the e-mailaddress of the endorsee. Use the business email address used by that endorsee and not any general or private e-mailaddress. The notification portal will send a verification mail in the next step.

To avoid any type errors

Fill in the number at which the endorsee can be reached. The Dutch Tax Authorities will only use this number to contact you in relation to the CbC notification and only if we cannot reach you using the e-mailaddress.

Choose any of the options given:

1. an ultimate parent entity residing in the Netherlands
2. an ultimate parent entity residing in another EU Member State
3. an ultimate parent entity residing outside the European Union
4. a surrogate parent entity residing in the Netherlands
5. a surrogate parent entity residing in another EU Member State
6. a surrogate parent entity residing outside European Union
7. a group entity residing in the Netherlands (local filing)
8. a group entity residing in another EU Member State, making use of local filing and being designated for filing on behalf of all other EU constituent entities
9. a group entity residing outside the EU wanting to make use of 'voluntary filing'.

Options 1, 3, 4, 6 en 7 are described in the document ‘20161017 CbCR_Manual Part 1 onofficiële vertaling’ which can be found on this website and on https://odb.belastingdienst.nl/ (paragraph 2.3).

Options 2, 5, 8 en 9 stem from European legislation and are described here: http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1477312766282&uri=CELEX:32016L0881 and https://www.oecd.org/tax/guidance-on-the-implementation-of-country-by-country-reporting-beps-action-13.pdf
These options will be implemented in Dutch law shortly.

If the ultimate parent entity is residing in one of the other EU Member States. In such a case the CbC report is automatically exchanged between all EU Member States.

If the surrogate parent entity is residing in one of the other EU Member States. In such a case the CbC report is automatically exchanged between all EU Member States.

If the group entity is residing in one of the other EU Member States, making use of local filing and being designated for filing on behalf of all other EU constituent entities, CbC reports are exchanged between all EU Member States. If no designation takes place, no exchange of the locally filed CbC report will take place, in which case there will be a local filing obligation in the Netherlands (group 5).

If a group entity residing outside the EU, files on behalf of all Constituent Entities and such country does not have a legal obligation to file a CbC report, but does allow for voluntary filing.

The name of the reporting Constituent Entity filing the CbC report on behalf of the MNE group. If you choose as type of reporting entity any of the options involving an entity resident in the Netherlands, the contact details of the Dutch resident notifying entity are copied. If that is incorrect because of a divergence, this data can be amended.

Fill in the country of residence of the reporting entity.

Fill in the Tax Identification Number of the reporting entity. If you choose as type of reporting entity any of the options involving an entity resident in the Netherlands, the TIN of the Dutch resident notifying entity are copied. If that is incorrect because of a divergence, this data can be amended.

Fill in the registered address for the reporting entity.

The house number for the registered address, excluding extensions.

Any extensions to the address.

This is the zip code / postal code relating to the address (without any spaces).

Fill in the city relating to the address for the reporting entity.

Fill in the registered address for the reporting entity.

The house number for the registered address, excluding extensions.

Any extensions to the address.

This is the zip code / postal code relating to the address (without any spaces).

Fill in the city relating to the address for the reporting entity.

If there is more than one group entity resident in the Netherlands which is part of the MNE group a list can be uploaded with e.g. names and addresses for these other group entities resident in the Netherlands. These lists have a fixed format and can be uploaded in Excel (XLSX) or OpenDocument (ODS). Please find attached templates for filing.

The list of group entities can be up to 20 Mb, should not be compressed, secured or include macro’s. Files that do not meet these criteria will be rejected.

If you file locally in the Netherlands (group 5), the Constituent Entity can opt for automatic exchange of the CbC report with other EU countries in which the group is active. If the Constituent Entity does not opt for such exchange, the group will need to check whether it has other local filing obligations within the EU as the CbC report will not be exchanged with other EU Member States.

Fill in the party filing the CbC report via the ‘Logius’ website of the Dutch tax Authorities (if filing in the Netherlands).

Select ‘A group entity, residing in the Netherlands’ if you are filing the CbC report yourself or ‘An endorsee’ if you are using a third party. If using a third party please provide their name and Becon number. If this party does not have a Becon number leave this field blank.

The name of the other Constituent Entities resident in the Netherlands per line.

The Tax Identification Number of the Constituent Entities resident in the Netherlands. This is the ‘RSIN’ by which the notifying Constituent Entity is registered with the Dutch Tax Authorities.

Fill in the registered address for the Constituent Entities resident in the Netherlands.

The house number for the registered address, excluding extensions.

Any extensions to the address.

This is the zip code / postal code relating to the address (without any spaces).

Fill in the city relating to the address for the reporting entity.

Fill in the postal address for the Constituent Entities resident in the Netherlands.

The house number for the postal address, excluding extensions.

Any extensions to the address.

This is the zip code / postal code relating to the address (without any spaces).

Fill in the city relating to the postal address for the reporting entity.

If you receive the e-mail confirming your notification, you may assume your list was received by us as well.

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