Measured in terms of accrual, not cash, the tax reached a total of 14,260 million for these groups, 15.5% of the benefit.

These data are included in the analysis prepared by the Tax Agency based on the information provided by the companies through the model 231 of declaration of information 'Country by country report' (CBC for its acronym in English) referred to to 2016, the first year in which this obligation of information was in force that aims to collect aggregate data of the collective for the exchange of information between tax administrations established in the agreements 'BEPS' ('Erosion of Bases and Transfer of Benefits') of The OECD The study is published on the Agency's website,

The analysis carried out by the Tax Agency, a pioneer worldwide, aggregates the information of the 134 groups and their 16,160 subsidiaries, including 10,967 foreigners, to maintain the confidentiality requirement established in the BEPS agreements themselves.

With the aim of transparency, it is thus intended to provide useful information for studies and analysis of the general public, and of researchers in particular, contributing to the international debate on the taxation of large corporate groups, on how to distribute it among the countries in which they operate and on the establishment of a tax land.

Effective worldwide taxation and distribution by tax rates

The analysis carried out affects Spanish parent groups that globally added 934.408 million euros in global turnover in 2016, with global net benefits incorporated by the companies to the CBC that totaled 91.849 million euros.

The tax paid by these 134 groups totaled 11,594 million in cash terms. The results show a large dispersion of effective rates on benefits. The statistics show that only 43 multinationals accounted for 49.1% of the benefit of the entire group and, however, only accounted for 10.5% of the total fee paid by the multinational group.

The CBC analysis is also carried out in terms of accrued tax. Accrued and paid taxes do not match because the calculation criteria are different.

In accrual, the tax will be the liquid quota of fiscal year 2016, formed by the sum of the installment payments and the differential installment of the same fiscal year 2016. Instead, the "paid" tax is the combination of the installment payments of 2016 and the differential share of 2015. This difference means that, for example, the tax credits applied that are included in one or the other concept (accrued and paid) are different.

Differences between Spanish statistics and the CBC

This study complements the information that the Agency has been publishing on the data declared in Societies by the individual companies and the Spanish consolidated groups.

Until now, the Tax Agency has been publishing statistics based on the data declared in the Corporate Income Tax in Spain, which present the effective rates to which companies and groups pay taxes in our country, calculating these rates both on the taxable bases of the tax as on the declared accounting results, including the latter also the income obtained abroad and likely to have been taxed in other countries.

Therefore, in the case of globalized companies, the information presented was not complete as information on their taxation is not yet available in the rest of the countries. With this CBC analysis, the information is completed since, for the first time, accrued taxes are published and those that are considered paid by large Spanish groups worldwide thanks to the 'Country by country' declaration.

In any case, the information referred to the CBC is not comparable with that existing in the statistics published by the AEAT on taxation in Spain, as there are large methodological differences.

The main difference lies in the concept of 'benefit' that the CBC includes and that contained in the Consolidated Annual Accounts of Companies published by the Agency. The CBC refers to a net profit; that is, once the losses of all the subsidiaries of a group in the same tax jurisdiction have been discounted.

On the other hand, in the Annual Accounts the gross profit is taken as a reference (it does not consider losses), which is understood as a more precise magnitude and close to the philosophy of a tax that only intends to tax positive results.

By taking the net benefits, discounting the losses, the resulting tax rates are higher than those obtained if the CBC included the gross profit.

What is the 'CBC'?

The 'Country by country' (CBC), or 'Country by country' information, is a model of informative declaration that multinational matrices with net consolidated business figures worldwide must present at their residence address 750 million euros. The information, which must affect the group of entities that are part of the tax group, is presented in Spain through the 231 declaration form and corresponds to the presentation to the Spanish-based multinationals.

The objective of the CBC is to collect aggregate and anonymized data from this group of large multinationals for the exchange of information established in actions 11 and 13 of the 'BEPS Agreements' (acronym in English for Erosion of Bases and Transfer of Benefits, so that States should be provided with a global perspective of the intra-group activity of their multinational elders.

The information submitted by the parent companies of all its subsidiaries abroad for the fiscal year beginning on January 1, 2016 includes the detail of the following variables for each of the jurisdictions (countries) in which they operate:

  • Number of entities (subsidiaries) that are part of the group
  • Business figure
  • Profits (losses) before taxes
  • Corporation Tax (paid and accrued)
  • Capital and reserves
  • Number of workers
  • Tangible assets (property, plant and equipment)

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