Recital (17)

The standard template for the Top-up tax information return set out in this Directive ensures that the information and tax calculations that an MNE group is required to file under the Top-up tax information return are sufficiently comprehensive to allow tax administrations to perform an appropriate risk assessment and to evaluate the correctness of a constituent entity’s tax liability under Directive (EU) 2022/2523. At the same time, it is sought to avoid imposing unnecessary information collection, computation and reporting requirements on MNE groups and to avoid exposing taxpayers to multiple, uncoordinated requests for further information in each implementing jurisdiction. A standardised Top-up tax information return does not affect the ability of a tax administration to require a routine domestic tax return or to collect information for the purposes of the preparation of the domestic top-up tax return, therefore Member States, in some cases, should be able to require additional data points to be reported beyond the Top-up tax information return for purposes of the preparation of the tax return (for example, to convert the top-up tax liability into the domestic currency). However, the Member States should generally refrain from requiring the reporting of additional data points beyond the Top-up tax information return as part of their routine domestic tax return and payment requirements and any such information should relate, for example, to liability, timing and method of payment or identification of the taxpayer and contact details, rather than the calculation of a constituent entity’s top-up tax liability. This Directive does not apply to domestic tax audit procedures and does not preclude tax administrations from requesting necessary supporting information in follow-up requests to verify compliance with provisions transposing Directive (EU) 2022/2523 under their national law.