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Practical Manual for Companies 2020.

Country-by-country information

The sole article, section three, of Royal Decree 1178/2020, of December 29, which modifies the Corporate Tax Regulations, 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 information country by country must request the corresponding information of the group from the non-resident entity.