While the general rule is that a constituent entity files a Top-up tax information return with its tax administration (local filing), Directive (EU) 2022/2523 provides a derogation pursuant to which a constituent entity is not obliged to file a Top-up tax information return with its tax administration if a Top-up tax information return has been filed by the ultimate parent entity or by a designated filing entity located in a jurisdiction that has, for the Reporting fiscal year, a qualifying competent authority agreement in effect with the Member State in which the constituent entity is located (central filing). This Directive constitutes such a qualifying competent authority agreement between Member States.
Text as published in the Official Journal, reproduced verbatim (including any typographical quirks of the source). For the authentic version, see EUR-Lex.
