Country-by-Country Reporting (CbCR) in Malta: Key facts and deadlines

CbCR enables tax authorities to identify potential transfer pricing and base erosion and profit shifting (BEPS) risks by providing a comprehensive picture of where an MNE group's income, taxes and business activities are located. However, the information is intended for high-level risk assessment purposes and is not a substitute for a detailed transfer pricing analysis.

Who is required to file?

CbCR applies to MNE groups with consolidated annual revenue of €750 million or more in the immediately preceding financial year. Groups below this threshold are exempt from the reporting requirement.

What information does the report contain?

The CbC Report consists of three tables:

1. Table 1: Financial and tax information by jurisdiction, including revenues, profits, taxes paid and accrued, employees, capital and tangible assets.
2. Table 2: A list of constituent entities and their main business activities by jurisdiction.
3. Table 3: Additional explanatory information to assist tax authorities in understanding the data reported.

Key filing deadlines

• The Ultimate Parent Entity (UPE) of an MNE group must file the CbC Report within 12 months after the end of the reporting fiscal year.

Notification requirements in Malta

Maltese constituent entities must submit an annual notification to the Malta Tax and Customs Administration (MTCA) indicating:

• Whether they are the reporting entity filing the CbC Report in Malta; or
• The identity and tax residence of the reporting entity filing on behalf of the MNE group.
• A Maltese Constituent Entity of a MNE Group that is not the Reporting Entity should file the CbC Notification Letter by the statutory tax return date of the respective fiscal year. For December year-end companies, this is due by 30th September.