The Direction Générale des Impôts (DGI) has issued a reminder of the December 31, 2022 deadline for country-by-country declarations. In accordance with the provisions of Article 154 ter of the CGI, country-by-country declarations must be filed electronically, using the model form drawn up by the tax authorities.
The so-called country-by-country declaration (articles 154 ter and 199 bis) concerns multinationals, and will apply to the financial year starting January 1, 2021. The declaration must be filed with the tax authorities in 2022.
Country-by-country reporting obligations apply to any multinational enterprise group with total consolidated group sales of DH8,122,500 or more, as shown in its consolidated financial statements, during the previous financial year.
We remind you that in the event of failure to file a country-by-country declaration or incomplete information, the company is invited by letter to regularize its situation within 15 days. If the company fails to do so, it is liable to a fine of DH500,000, issued by way of assessment (article 199 bis).
This declaration will give tax authorities a global view of the operations of multinational groups. Tax authorities can use this information to carry out high-level assessments of transfer pricing risks, etc.
What you need to know :
- It applies to the 2021 financial year and must be filed with the DGI in 2022.
- Automatic exchange with foreign tax jurisdictions from 2023
For further information on country-by-country reporting, please contact our legal and tax team.
Faithfully yours,
Ilham Taha-Bouamri
Chartered accountant and tax specialist
