Country-by-country information

The single article, section three, of Royal Decree 1178/2020, of December 29, which modifies the Corporate Tax Regulation, approved by Royal Decree 634/2015, of July 10, modifies section 1 of article 13 of RIS , in the following sense:

• In letter b) of article 13.1 of the RIS establishes that entities resident in Spanish territory dependent, directly or indirectly, on a non-resident entity in Spanish territory that is not at the same time dependent of another, as well as the permanent establishments in Spanish territory of non-resident entities of the group must provide the information country by country when, among other cases, there is an international agreement in the sense of the Directive ( EU ) 2016/881 of the Council of 25 May 2016, amending Directive 2011/16/EU with regard to the mandatory automatic exchange of information in the scope of taxation , with the country or territory in which the aforementioned non-resident entity fiscally resides, there is no agreement for the automatic exchange of information between competent authorities , regarding said information, with the aforementioned country or territory.

• It is added that the entity resident in Spanish territory or the permanent establishment in Spanish territory obliged to present the country-by-country information must request the corresponding information of the group from the non-resident entity.