Country-by country report is a report concerning multinational enterprise groups which includes aggregate information on multinational enterprise groups relating to the amount of revenue, profit or loss before income tax, income tax paid and income tax accrued, stated share capital, accumulated earnings, number of employees and tangible assets other than cash or cash equivalents with regard to each such state and jurisdiction in which the multinational enterprise group operates. This report also includes information enabling identification of the members of the multinational enterprise group, including information concerning the state or jurisdiction of tax residency of the member of the group or under the legislation of which it is formed if it is different from the jurisdiction of tax residency, and information on the main business activities of the members of the group.

An Estonian tax resident corporation is deemed a reporting entity, if it’s consolidated turnover is 750 million euros or in excess of EUR 750 million euros and it engages in cross-border activities (also a permanent establishment). The reporting entity as a rule is the group’s parent company, if the parent company does not fulfil its obligation then other reporting entity that is a tax resident of Estonia has an obligation of communication of all information required for the performance of the reporting obligation or submit the country-by country report also in the case of a failure to obtain all the information required to perform the reporting obligation.

The reporting entity that is a tax resident of Estonia has to collect the information necessary for submission of the country-by-county report specified  in Tax Information Exchange Act and submit the country-by-county report to the tax authority by 31 December of the calendar year following the financial year that is a reporting year.

In the case the group has more than one member that complies with the definition of the reporting entity, the group has to notify the tax authority of the appointment of one member of the group to submit the county-by-country report on behalf of the group. Such member of the group shall be ensured access within the group to all the information that is required for submission of the country-by-country report. Each member of the group that is a tax resident of Estonia shall notify the tax authority whether it is a reporting entity.

If a member of the group that is a tax resident of Estonia is not a reporting entity, it notifies the tax authority of which of the members of the group is a reporting entity and of the tax residency of such entity.

The notification obligation shall be performed within six months as of the end of the financial year that is the reporting year of the group.

Failure to comply with the obligations of the information provider (reporting entity) and information source provided (non-reporting entity) for in the Tax Information Exchange Act is punishable by a fine of up to up to 3,200 euros.


For further information on Country-by-country reporting and resulting reporting obligation please contact

Alice Salumets, Partner (Estonia), e-mail alice.salumets(at)roedl.com, phone +372 6068650

Verner Silm, Attorney, e-mail verner.silm(at)roedl.com, phone +372 606 8650