Public CbC Report

On 11 November 2021, the European Parliament formally adopted the public EU country-by-country (CbCR) reporting directive (“Directive”). All EU countries were required to transfer the Directive into domestic legislation as of 22 June 2023. Following this, multinational groups, and where relevant, certain standalone undertakings, should provide the public with a report on income tax information where they exceed a certain size, in terms of the amount of revenue, over a period of two consecutive financial years, depending on the consolidated revenue of the group or the revenue of the standalone undertaking.

The suggested timeline of the EU Directive was to publicly disclose the information for financial years starting on or after 22 June 2024 for most groups, resulting in a first reporting obligation for the financial year to 31 December 2025 no later than 12 months after the period end, i.e. by 31 December 2026. In practice, for MNEs that apply a financial year equal to the calendar year, the first reporting year will be 2025.

Romania became one of the first EU Member States to implement the Directive, making it applicable for accounting periods starting from 1 January 2023.

National legislative basis of the Public CbCR in Romania:

•  Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation (DAC 4);
• Government Decision No. 387/2018 for the approval of the Multilateral Agreement of the competent authorities for the exchange of Country-by-Country Reports, signed in Bucharest on December 19, 2017 
• Law 207/2015 on the Fiscal Procedure Code, with subsequent amendments and additions, art. 291^3 – The scope and conditions of the mandatory automatic exchange of information regarding the Country-by-Country Report;
• Order of the President of the National Fiscal Administration Agency no. 3049/2017 regarding the approval of the model and contents of the form for „Country-by-Country Reporting”, with subsequent amendments and additions.

Public CbCR available on the below link provides information on the: i) ultimate parent company of SoftwareONE Licensing Experts SRL; ii) the currency and language used; iii) list of consolidated subsidiaries of the SoftwareOne Group; iv) a brief description of the nature of their activities; v) number of employees in full-time equivalents; vi) income, gross profit or loss(s), income tax accrued, income tax paid, accumulated earnings at the end of the financial year, total revenue, except for dividends received from entities within the group, accrued earnings refer to profits from the previous and the current financial year, whose distribution has not been decided.