Introduction

Country by Country (CBC) statistics are based on the use of Form 231 for reporting Country by Country information, which arises as a result of the so-called "BEPS" Action Plan, i.e., "Base Erosion and Profit Shifting", which is drawn up within the Organisation for Economic Co-operation and Development (OECD), and specifically in relation to Action 13 on reporting and documentation of related parties and transactions, the aim of which is to provide tax agencies with control tools to ensure that profits are taxed where economic activities are effectively carried out and value is generated. This obligation to submit the country-by-country report is applicable for tax periods beginning on or after January 1, 2016.

This declaration model must provide, among other variables, the level of income, profits before taxes and the amount of corporate tax accrued and paid in each of the tax jurisdictions in which the multinational groups carry out their activities. Parent companies of multinationals with a consolidated net turnover worldwide equivalent to or greater than 750 million euros for all entities that form part of their group are required to file it in their tax domicile.

The statistics consist of a group of tables that present, according to different classification variables, the aggregated information by jurisdiction collected in the declaration. In this sense, each reporting entity integrates the figures for all companies that form part of the group, regardless of their tax domicile. Additionally, data from all subsidiaries located in the same jurisdiction are grouped together, providing the greatest disaggregation of available information. Therefore, Form 231 does not provide individualized data for member companies, but rather individualized data for groups by jurisdiction.