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Please indicate the total annual consolidated income of the group as at date

The term “Ultimate Parent Entity” means a Constituent Entity of an MNE Group that meets the following criteria:

• it owns directly or indirectly a sufficient interest in one or more other Constituent Entities of such MNE Group such that it is required to prepare Consolidated Financial Statements under accounting principles generally applied in its jurisdiction of tax residence or would be so required if its equity interests were traded on a public securities exchange in its jurisdiction of tax residence; and
• there is no other Constituent Entity of such MNE Group that owns directly or indirectly an interest described in subsection (i) above in the first-mentioned Constituent Entity.

The term “Reporting Entity” means the Constituent Entity that is required to file a country-by-report conforming to the requirements in Article 4 in its jurisdiction of tax residence on behalf of the MNE Group. The Reporting Entity may be the Ultimate Parent Entity, the Surrogate Parent Entity, or any entity described in paragraph 2 of Article 321/1 ITC.

The term “Surrogate Parent Entity” means one Constituent Entity of the MNE Group that has been appointed by such MNE Group, as a sole substitute for the Ultimate Parent Entity, to file the Country-by-Country Report in that Constituent Entity’s jurisdiction of tax residence, on behalf of such MNE Group, when one or more of the conditions set out in article 321/2, §2, al.1 apply.

Conditions:

• The jurisdiction of which the Surrogate Parent Entity is a tax resident requires the filing of a country-by-country report;
• No later than 12 months after the last day of the reporting period for which the country-by-country report has to be filed, the jurisdiction of which the Surrogate Parent Entity is a tax resident has an eligible agreement between competent authorities in force which Belgium is a part of;
• The jurisdiction of which the Surrogate Parent Entity is a tax resident has not informed the Belgian administration responsible for the establishment of income tax of a systematic failure;
• The jurisdiction of which the Surrogate Parent Entity is a tax resident has been informed, has prescribed by article 321/3 §1, by the constituent entity which is a tax resident of this jurisdiction that this constituent entity is the Surrogate Parent Entity; and
• A notification has been addressed to the Belgian administration responsible for the establishment of income tax as prescribed by article 321/3, § 2.

Conditions:

• The Ultimate Parent Entity (or the Surrogate Ultimate Entity) of the MNE group is not required to file a country-by-country report in the jurisdiction of which it is a tax resident; or
• No later than 12 months after the last day of the reporting period, the jurisdiction of which the Ultimate Parent Entity (or the Surrogate Ultimate Entity) is a tax resident has no eligible agreement between competent authorities in force which Belgium is a part of; or
• The Belgian administration responsible for the establishment of income tax has informed the Belgian constituent entity of a systematic failure from the jurisdiction of which the Ultimate Parent Entity (or the Surrogate Ultimate Entity) is tax resident.