Country-by-Country Reporting: Penalties
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The recently published amendments to the Cooperation with Other
Jurisdictions on Tax Matters Regulations introduce
penalties for non-compliance with Maltese Country-by-Country
reporting (CbCr) obligations. CbCr is a tax compliance obligation
that requires MNEs to annually file a comprehensive group tax
report to cover every jurisdiction where they have a tax
All Maltese Constituent Entities (irrespective of whether they
fall under the obligation to file CbCr or not) must notify the CfR
about the MNE entity who will be filing the CbCr by no later than
the last day for filing of a tax return of that Maltese Constituent
Entity for the preceding fiscal year.
Failure of a Maltese Constituent Entity to inform the CfR of the
entity who will be filing the CbCr or to inform that such a
Constituent Entity falls under the obligation to file the CbCr in
its respective capacity, will result in the penalty of €200
and €50 for every day of non-compliance to each stated
The total penalty is capped at €5,000 for non-compliance to
each stated obligation separately.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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