Country-by-Country Reporting (CbCR) is a tax-transparency tool aimed at large multinational groups with consolidated revenues of at least EUR 750 million. Both Slovakia and the Czech Republic implement it under the same OECD BEPS Action 13 framework and the EU DAC4 directive, so the core threshold and logic are identical. The practical differences lie in the notification mechanics and deadlines, which every local subsidiary of a large group should know.
What is Country-by-Country Reporting?
CbCR emerged as Action 13 of the OECD BEPS project and entered EU law through the DAC4 directive (2016/881/EU). It gives tax administrations a country-by-country breakdown of where a multinational group earns revenue, pays tax and employs people. If profits accumulate in low-tax jurisdictions while the real activity sits elsewhere, the report makes it visible. The data is automatically exchanged between tax administrations and used to select groups for transfer-pricing audits.
In Slovakia the rules sit in Act No. 442/2012 Coll. on international assistance and cooperation in tax administration; in the Czech Republic in Act No. 164/2013 Coll. on international cooperation in tax administration. The substance is harmonised because both transpose the same EU directive.
Who does the EUR 750 million threshold apply to?
What matters is the consolidated revenue of the whole group, not the turnover of a single local company. If the group reached at least EUR 750 million in consolidated revenue in the preceding accounting period, it falls within CbCR in both countries. This captures only a fraction of companies, in practice the local subsidiaries of large international groups.
The most common mistake is identical on both sides of the border: a small Slovak or Czech s.r.o. assumes it is too small to be concerned, yet if it belongs to a group that crosses the threshold, the notification obligation applies to that subsidiary too. The same logic underpins the local documentation duties described in our guide to transfer pricing documentation in Slovakia and the Czech Republic.
Notification versus the report itself
Both countries separate two obligations. The notification is filed by each local group member and states which group entity, in which country, will file the actual report. The country-by-country report (the figures) is filed by the ultimate parent for the whole group. For most local subsidiaries this means one thing: they do not file the report, but they must file the notification.
How do the deadlines differ?
This is where Slovakia and the Czech Republic diverge in the details:
- Slovakia: the notification is due within the deadline for the corporate income tax return, i.e. generally within three months after the end of the tax period; the report is due within 12 months of the end of the group’s reporting period.
- Czech Republic: the notification (ohlášení) is due by the end of the first reporting accounting period, with a new notification filed by the end of the reporting period in which the details change; the report is due within 12 months of the end of the reporting period.
In both countries filing is fully electronic through the tax portal. The 12-month deadline for the report itself is the same, so the divergence concerns mainly the notification timing.
What does the report contain?
For each country the group reports revenue (from related and unrelated parties), profit or loss before tax, income tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets, plus a list of all group entities and their activities. This lets a tax authority quickly spot a mismatch, such as high profit and zero employees in a low-tax country.
Penalties and public CbCR
Slovakia can impose a fine of up to EUR 3,000 for failing to file the notification, repeatedly until the duty is met; the Czech Republic imposes fines under its own tax-cooperation act. On top of the confidential regime, the EU directive 2021/2101 introduces public CbCR, transposed into the accounting acts of both countries, under which selected large groups must disclose part of the data publicly. Groups therefore need their published figures to stay consistent with their transfer-pricing position.
Not sure whether your Slovak or Czech company, as part of an international group, must file a CbCR notification and by when? We are happy to assess it and set up the full reporting calendar for you.
FAQ
Does a small local subsidiary have to file CbCR?
It does not file the report itself, which the parent submits for the whole group. But if the subsidiary belongs to a group with consolidated revenue above EUR 750 million, it must file the notification stating which entity reports and where. This applies to small subsidiaries of large groups in both Slovakia and the Czech Republic.
What are the deadlines?
In Slovakia the notification follows the corporate tax return deadline (generally three months after the period ends). In the Czech Republic the notification is due by the end of the first reporting period, with a new notification filed by the end of the reporting period in which the details change. In both countries the report itself is due within 12 months of the end of the group’s reporting period.
What is public CbCR?
Public CbCR stems from EU directive 2021/2101 and requires selected large groups to disclose part of their country-by-country data publicly, not only to tax authorities. Both Slovakia and the Czech Republic have transposed it into their accounting legislation, adding a second layer of reporting alongside the confidential regime.