Country-by-Country (CbC) Reporting requirements are introduced for reporting fiscal years beginning on or after 1 January 2018.

The CbC reporting requirements are applicable to resident parent companies of groups meeting a EUR 750 million consolidated group revenue threshold, as well as non-parent constituent entities resident in Andorra if:

• The foreign ultimate parent company is not required to file a CbC report in its jurisdiction of tax residence;
• The parent's jurisdiction has an international agreement for the exchange of information in force with Andorra but does not have a competent authority agreement for the exchange of CbC reports; or
• There has been a systemic failure for exchange and the non-parent constituent entity has been informed;

Where more than one non-parent constituent entity is required to submit a CbC report, one may be designated to fulfill the obligation, although, the local filing obligation will not apply if a surrogate parent entity has been designated to file and certain conditions are met, including that the report will be exchanged with Andorra and notification has been provided.

A CbC notification is required to be provided to the Andorran authorities by the tax return deadline for the reporting fiscal year, including whether an entity is the ultimate or surrogate parent, and if neither, details of the identity and tax residence of the reporting entity.

The content of the CbC report is in line with BEPS Action 13 guidelines and is required to be filed within 12 months after the end of the reporting fiscal year. Failure to comply with the CbC reporting requirements, including notification, results in penalties of EUR 1,000 for the first offence and EUR 3,000 for subsequent offences.