The scope of this obligation to file the Country-by-Country Report in Honduras will apply when the jurisdiction where the ultimate parent entity is located has consolidated its financial statements and exceeded 750 million euros in local currency.
This new requirement takes effect for the Reportable Fiscal Years of Multinational Groups beginning on or after January 1, 2025.
Who is required to file the Country-by-Country Report:
- Any ultimate parent entity of a multinational group that is resident for tax purposes in Honduras must file a Country-by-Country Report with the Tax Administration for its reportable fiscal year.
- A Constituent Entity that is not the Ultimate Parent Entity of a Multinational Group must file a Country-by-Country Report with the Tax Authority for the Reportable Fiscal Year of the Multinational Group of which it is a Constituent Entity, provided the following criteria are met:
- such entity is resident for tax purposes in Honduras; and
- one of the following conditions is met:
a) the Ultimate Parent Entity of the Multinational Group is not required to file a Country-by-Country Report in its jurisdiction of tax residence; or
b) the jurisdiction of tax residence of the Ultimate Parent Entity has an international agreement in force to which Honduras is a party, but does not have an eligible agreement between competent authorities in force to which Honduras is a party (regarding the filing of the Country-by-Country Report for the Reportable Fiscal Year); or
c) the jurisdiction of tax residence of the Ultimate Parent Entity has committed a Systematic Omission that has been notified by the Tax Administration to the Constituent Entity resident for tax purposes in Honduras.
On the other hand, when several Member Entities of the same Multinational Group are tax residents in Honduras and one or more of the specified conditions apply, the Multinational Group may designate one of those Member Entities to file the Country-by-Country Report with the Tax Administration in relation to a Reportable Fiscal Year.