Definition of

IOTA Report for Tax Administrations

 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

DEFINITION OF ‘LARGE TAXPAYER’

IOTA Report for Tax Administrations

Intra-European Organisation of Tax Administrations (IOTA)

Budapest 2008
 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

BACKGROUND

IOTA as one of the major international organisations working in the field of tax
administration committed itself, besides all its other activities, to issuing
publications on selected topics to inform interested tax officials from IOTA Member
tax administrations and other readers working in or dealing within tax
administration issues.

Publications are published as downloadable documents from the IOTA website

(www.iota-tax.org) and/or as a printed version available for IOTA Members only.

Based on information from 39 Member tax administrations, IOTA publications

enable the reader to have a view on most of the European tax administrations and
compare approaches in dealing with various aspects of tax administration.

The focus of IOTA publications is always on the area of administration itself and
does not cover policy issues; IOTA Good Practice Guides, Reports or Comparative
Studies are not intended to prescribe any of the procedures or treatments detailed,
but unfold an overview on the differences of the tax administrations in addressing
and tackling problems and daily work in their organisations. It is up to the
individual tax administration to draw any conclusion from the publication and make
decisions taking account of their own domestic situation.

Given the financial and human resources, the publications will be updated on a
regular basis should the topic make it necessary.

All proposals for amendment/additional information from readers that will increase
the value of the document are appreciated and should be send to the IOTA
Technical Advisory Committee, TechnicalActivities@iota.hu.

The idea for publication of this report was born in one of the meetings of the Area
Group Large Taxpayer Treatment and Audit (LTTA) in 2003; for a number of reasons
the first draft was not published but was used as a working paper for one of the
plenary meetings of the Area Group.

A significant number of tax administrations within IOTA, and elsewhere in the

world, have already decided to implement special units or divisions that deal with
their countries’ large taxpayers; offering a complete set of services creates a win-
win situation for taxpayers and tax administrations particularly by reducing
administrative costs

The investigation and description of the definitions of large taxpayers was seen as a
valuable topic offering a view on the different practices within the IOTA
membership.

In May 2007 it was decided to update the information already collected and to
publish the result as a report on the new IOTA website for the use of tax officials.
The work was done by a group of colleagues, mostly Area Group members but
 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

supported by experts appointed by their tax administration exclusively for the

purpose of this report.

Based on the 2003 document the Task Team drafted a questionnaire which was sent
to all IOTA Member tax administrations; responses to the questionnaire were
received from 30 Member tax administrations represented in the Area Group; only
nine Member administrations did not respond to the questionnaire, mostly because
they had not created large taxpayer units within their organisations. The analysis of
the responses led to the creation of the document accessible for those IOTA
Member tax officials who are registered users of the website.

As well as all the colleagues who did their best to complete the questionnaire with
relevant and valuable answers we would particularly like to highlight the excellent
work of the Task Team that produced this report, Marja Hälli (Finland), Daniel
Bovigny (Switzerland), Tea Haaviste (Estonia), Maria Gabriella Lusi (Italy),
Liliana Manea (Romania), Aniko Réfi (Hungary), Lidija Stojanovic (Serbia),
Danijela Tesic (Republic of Srpska of B&H) and Vanessa Mauri (Switzerland).

This questionnaire was constructed in such a way as to answer the question of how
the Member tax administrations of IOTA defined the term Large Taxpayer.

The report reflects the situation in IOTA Member administration at the end of
December 2007.

Should readers require any country related clarification please contact the
Technical Advisory Committee of IOTA (see email details above).

Budapest 15 December 2007

Area Group Large Taxpayer Treatment and Audit
Intra-European Organisation of Tax Administration
 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

TABLE OF CONTENTS

1. Definition of the Term ‘Large Taxpayer’...............................................5

2. Criteria Used in Defining a Large Taxpayer ............................................6

2.1. General....................................................................................... 6
2.2. Criteria applied............................................................................. 6
2.3. Other criteria used......................................................................... 9

3. How Often Do You Update the List of Your Large Taxpayers? .................... 11

4. How Long are They Treated as a Large Taxpayer Even if They Do Not Meet the
Criteria? ......................................................................................... 13

5. Number and Percentage of Registered Large Taxpayers .......................... 14

5.1. Number of registered large taxpayers ................................................. 14
5.2. The percentage of registered large taxpayers ....................................... 15

6. Further Information...................................................................... 17

7. List of Annexes ........................................................................... 19

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

1. DEFINITION OF THE TERM ‘LARGE TAXPAYER’

The questionnaire 1 prepared by the Task Team “Definition of Large Taxpayers”

asked whether there is a legal definition of the term ‘large taxpayer‘ in IOTA
Member countries and if so, requested that the text of the legal definition should
be provided. It also asked whether other definitions or guidance for the term ‘large
taxpayer’ are used in administrations and if so, the respondents were requested to
provide details of these definitions.

According to the responses:

• 45 % of the countries have a legal definition;
• 45 % of the countries use other definitions or guidance to define the term
large taxpayer;
• 10 % of the countries have no definition or other description of so called
large taxpayer.

In the case of most of those countries that have a legal definition it is generally
part of the Act or Rules on Taxation, but there are also countries where the term is
defined in some other Act like VAT or Accounting in the Code of Commerce.

Further definitions or guidance are provided by internal or administrative rulings of

the tax administration or in some cases guidance issued by the Ministry of Finance.

In certain countries there are different definitions depending upon whether for
audit or taxation purposes.

In those countries that do not have either a legal or any other definition or
guidance then there is no separate unit to handle large taxpayers. The number of
these countries has significantly decreased in the last few years.

1 The questionnaire is attached to the report as Annex I.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

2. CRITERIA USED IN DEFINING A LARGE TAXPAYER

2.1. General

In the part of Questionnaire relating to the criteria used for identifying large
taxpayers (questions 3 and 3a), the Task Team set out five factors that could be
used to indicate what defines a large taxpayer.

Those responding "other“ as the sixth criterion, were invited to give a further
explanation of the specific factors used, at question 3a.

At this point it is useful to give some important information relating to the

methodology and analysis used in the treatment of answers in order to better
understand the results.

The complete questionnaire has been considered, not just the responses to
questions 3 and 3a, in consideration of the complexity of questions and detailed
information through the answers to other questions which are important for the
final analysis of criteria. In that manner the problem of some illogical and
inconsistent answers has been overcome.

Regarding the fact that the concept of large taxpayer or large business is defined in
several laws (Accounting Law, Audit Law, Tax Law etc.) and that the answers
contain the mentioned information as well, in the analysis the criteria and values
given in the tax laws have been accepted.

2.2. Criteria applied

Through analysis of the answers to question no 3 “What criteria do you use for
defining the large taxpayers” the following conclusions can be drawn.

• No country exclusively uses one measure for defining a large taxpayer; it

is usually a combination of several different ones.

Most often, it is not necessary to meet them all (except for Spain and Serbia – legal
status and turnover and legal status and the tax paid), usually for the status of a
large taxpayer to apply it is necessary to meet only some of the criteria.

For example, in Latvia, it is necessary to meet three of the five criteria and in Belgium,
two of three.

• In some countries the same criteria applies for all business activities and
types of public revenue, while in other countries different criteria apply
depending on the business activity, the type of tax and the tax
administration’s objectives. Also, in some countries there are criteria for
defining large taxpayers for administration and management that are
different from the criteria for audit purposes.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

In Germany, for example, turnover and profit are the measures for defining large
taxpayers within the commercial, production and independent professions sectors;
turnover is the criterion for insurance companies and non-profit organizations; profit and
assets are the criteria for banks and farmers, whilst positive income applies for wealthy
persons.

In the United Kingdom, the selection of criteria is based on the tax type: for the
corporation tax (gain), the criteria are risk analysis or size and complexity of accounting,
organization and business, as well as behaviour related to the tax planning and tax
evasion, for salary taxes and contributions the criterion is the number of employees, for
the Petroleum Revenue tax there isn’t any criterion, but all the businesses registered for
this activity, all payers are large taxpayers, and for VAT, excises, customs and
environmental taxes, the criterion is a so-called VAT throughput or the tax paid.

In Ireland, the criteria for companies and company groups are turnover and paid tax, and
for high wealth individuals, the criteria are net assets, income or substantial economic
interest in Ireland.

• The criteria may depend on the tax administration’s objectives.

In France for example, the criteria for defining large taxpayers (turnover and related
persons) for administration purposes are different from the ones for the audit function,
where the large taxpayers are all banks, insurance companies and other financial
institutions.

In the United Kingdom, a business or a taxpayer that does not meet any criterion might be
treated as a large one, when it is for the purposes of including the complete profile of one
sector.

• The criteria values (thresholds) may also be unique for all activities or
types of public revenue, or within the same criterion, there may be
defined different value levels as the starting ones, depending on the
activity type and types of public revenue.

In the Netherlands for example, for the criterion “total turnover” the value varies
depending on the business activities:
• All the taxpayers with more than EUR 25 million;
• Foreign parent company - EUR 12.5 million;
• Governmental organisations, cities and hospitals with more than EUR 37.5 million.

It is similar in Denmark:
• All the taxpayers with more than EUR 400 million as the total turnover;
• Companies for electricity production with more than EUR 267 million;
• Companies using the ’Tonnage-scheme’, more than EUR 400 million etc.

An interesting example was reported from Norway where the defined criteria for the large
taxpayers is not select strictly linked to the values of those criteria, but where the status
of a large taxpayer belongs to the “largest ones” according to each criterion.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

As a criterion for defining the large taxpayers:

• “Total turnover” is most popular –79%;
• The second equal are the “number of employees” and due tax paid – by 29%;
• The assets value – 18%;
• The profit criterion – 4%.

Criteria used to define Large

Taxpayer

120% 100%
100% 79%
80%
60%
40% 29% 29%
18%
20% 4%
0%
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ee

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Apart from the different industry sectors, the legal status of the taxpayer and the
status of consolidation IOTA Member administrations use other criteria for defining
a large taxpayer; the following categories are in use as well:
• Net assets and income of high wealth individuals (Ireland);
• Complex structure and organization of taxpayers (Latvia);
• Annually paid salaries (Sweden);
• Complexity of accounting and business and establishing of sector profile
(UK);
• Special interest and the tax administration’s objective (Czech Republic);
• Non- profit organizations and companies (Belgium); and
• Norwegian taxpayers owning and controlling companies in the countries of
the tax haven (Norway).

In a few countries there are very particular criteria. In France a company is considered as
a large taxpayer if it is entered in a tax ruling or member of a domestic tax consolidation.
In Finland all European companies created as “Societas Europaea” (SE) are considered as
large taxpayer.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

2.3. Other criteria used

Implementation and types of “other criteria” for definition of large taxpayer are at
the same time the starting point to analysis of the answer to question 3a.

„Which are the other factors being used for defining the large taxpayers?” that
reflect the specific qualities of the tax administrations in defining the large
taxpayers.

The legal status is irrelevant in 28.6% of countries, only Ireland and Germany
include individuals as large taxpayers; in 42.9% of cases the large taxpayers are
only LTD companies and in 39.3% of countries into the legal status as a requirement
are not included either individuals or LTD companies, but other types, mostly
specific types of related persons (France) or targeted sector groups (Netherlands).

The next criterion in defining the large taxpayer is the inclusion of multinational
companies into the large taxpayers, independently of meeting of other criteria;
28% of the Member administrations implemented it.

36% of countries, stock exchange companies, independently of meeting of other

criteria, have the large taxpayer status.

More common as a used criterion are companies related in a group (40%); included
in that figure as well and irrespective from meeting of other criteria a smaller
number of countries (32%) treats the “Group” of related companies as one single
large taxpayer. In countries where “Group” is a criterion considering taxpayers as
large taxpayer the utilised concept of “Group” is different.

“Groups” treated as one large taxpayer as a further criterion (in this questionnaire)
is considered exclusively linked to the criteria of definition. Some Member tax
administrations also have a group taxation regime but it is not the topic of this
report. There are there different versions to be mentioned:
• One member of a “Group” fulfils the criteria itself, and but all its related
bodies are treated by the Large Taxpayer Unit (LTU) to handle/audit them
together (Belgium).
• One member of the “Group” is a large taxpayer and its tax returns
containing not only its own data, but also the figures of its related
companies (France).
• The members of a “Group” do not fulfil the criteria (by oneself), but
together they reach the criteria to be treated as a large taxpayer by the tax
administration (Finland, Austria and Sweden).

In some countries the status being a large taxpayer depends on the formal
obligation to issue a consolidated annual report (Belgium, Finland and Greece).

In other countries the percentage of shares is the used measurement.

In France large taxpayers are companies linked with a percentage more than 50% of shares
in an entity respecting the criteria for individual company.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

In Sweden the consolidated amount of salary is considered as a valid criterion.

Finland classifies as large taxpayer all groups of companies generating turnover more than
EUR 50 million.

In the Netherlands a large taxpayer is a foreign mother company or a taxpayer controlling

at least 5 foreign subsidiaries and/or permanent establishments and paid taxes more than
EUR 12.5 million.

Finally, the most important criterion implemented in 82% of IOTA Member tax
administrations, is the type of business activity or economic and industry sector, on
which basis all the companies from those activities are defined as large taxpayers.
Included sectors included directly into the large taxpayers depends both on their
importance of the industry sector in national economies and on interest and policy
of each country.

75 % of reported activities are related to financial services like banks, insurance

companies or funds; production of petroleum and gas is reported back by 10%; the
same percentage of seven percent is valid for the sectors of gambling and
producing energy, and as particular cases the export-import sectors in the
wholesale, IT sector and advertising, shipping companies, chemicals, hydrocarbon
companies and production, import and distribution of excise products were
mentioned in the responses to the questionnaire.

Branches/Sectors used to define Large Taxpayer

80% 75%
70%
60%
50%
40%
30%
20%
10% 7% 7%
10% 3%
0%
1 2 3 4 5
Financial services Petroleum & gas Games of chance Energetics Other

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

3. HOW OFTEN DO YOU UPDATE THE LIST OF YOUR LARGE TAXPAYERS?

How often do you update the list of your large

taxpayers?

80% 72%
70%
60%
50%
40%
30%
20% 14%
7% 3% 3% 3%
10%
0%
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Ev

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Ev

Ev
Ev

Member tax administrations implemented different periods for the review of the
criteria to include taxpayer in the group of large taxpayers. Based on internal and
domestic parameters the period goes down to permanent amendment of the
classification starting from a five years period. Most of the administrations consider
the updating of the classification as very important as more than two thirds of the
responding countries implemented the one year review approach.

The following list of approaches provides an overview of the used systems in the
IOTA membership.

72% of the respondent administrations update the list of their large taxpayers every
year (21 Member administrations: Albania, Austria, Belgium, Croatia, Czech
Republic, Denmark, Estonia, Hungary, Ireland, Italy, Latvia, Lithuania, Norway,
Republic of Srpska, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland and
The United Kingdom).

14% of the respondent administrations update the list of their large taxpayers every
two years (four tax administrations: Bulgaria, Ireland, the Netherlands and Serbia).

7% of the respondent administrations update the list of their large taxpayers every
three years (two tax administrations: Finland and Germany).

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

3% of the respondent tax administrations update the list of their large taxpayers
every four years (one tax administration - Greece).

3% of the respondent tax administrations update the list of their large taxpayers
permanently (one tax administration - France).

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

4. HOW LONG ARE THEY TREATED AS A LARGE TAXPAYER EVEN IF THEY DO NOT
MEET THE CRITERIA?

How long are treated as a large taxpayer even if

they don't meet the criteria?

50%
41%
40%
31%
28%
30%

20%

10%

0%
One year Two years Other

Consequently linked to the review period of the classification of taxpayer the

duration of the status is defined. Based on the replies of the Member
administrations the following overview can be presented.

28% of the respondent administrations treated as a large taxpayer one more year
(eight Members: Croatia, Denmark, Ireland, Italy, Norway, Serbia, Spain and
Sweden).

31% of the respondent administrations treated as a large taxpayer two more years
(nine Member tax administrations: Albania, Belgium, Bulgaria, Estonia, Greece,
Ireland, the Netherlands, Romania and Slovakia).

41% answered they treated them as large taxpayer some other period:
• For the full audit period up to 5 years (Austria).
• The tax audit system can wait until the tax audit of the last fiscal year
considered (France).
• One year or less. Until the next update of the list of the companies
administrated by the Large Taxpayers Department, but the other companies
are administrated by the County State Tax Inspectorate and treated as
regular taxpayers (Finland and Lithuania).
• Immediately: Slovenia and Republic of Srpska.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

5. NUMBER AND PERCENTAGE OF REGISTERED LARGE TAXPAYERS

5.1. Number of registered large taxpayers

40.00%

35.00%

30.00%

25.00%

20.00%

15.00%

10.00%

5.00%

0.00%
less 100 between 100-1000 between 1000-10000 between 10000-100000 over 100000

The established figures vary between 45 large taxpayers in Switzerland and 258
large taxpayers in Lithuania up to 179,765 large taxpayers in Germany.

The number of registered large taxpayers is:

• Between 0 and 100 large taxpayers in one country (Switzerland) – 4% of the
responded member tax administrations;
• Between 100 and 1,000 large taxpayers in ten countries (Bulgaria, Estonia,
Hungary, Latvia, Lithuania, Republic of Srpska, Romania, Serbia, Slovakia,
Slovenia) – 36% of the responded Members;
• Between 1,000 and 10,000 large taxpayers in nine countries (Albania,
Croatia, Czech Republic, Denmark, Finland, Greece, the Netherlands,
Norway, The United Kingdom) – 32% of the responded Members;
• Between 10,000 and 100,000 large taxpayers in seven countries (Austria,
Belgium, France, Italy, Ireland, Spain, Sweden) – 25% of the responded
Members;
• 100,000 and more large taxpayers in one country (Germany) – 4% of the
responded Members. As in Germany wealthy individuals are also considered
as Large Taxpayers, which explains why the amount of large taxpayers is so
high.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

In France there are 66,000 registered large taxpayers for the tax audit and 35,000 for the
tax management, because there are different criteria for the DGE (directorate in charge of
the monitoring of LTP) and criteria for DVNI (Tax audits directorate).

5.2. The percentage of registered large taxpayers

70%
64%
60%

50%

40%

30%

20%
14% 14%
10% 8%

0%
less 1% between 1 -2% between 2-4% over 4%

64% of the member administrations large taxpayers percentage ratio compared to

the general amount of the taxpayers is less than 1% (17 countries: Bulgaria, Czech
Republic, Estonia, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Norway,
Romania, Serbia, Slovakia, Slovenia, Spain, Switzerland, the United Kingdom). One
important reason is that these 18 member administrations a “Group” of related
companies are not treated as one large taxpayer.

In 14% of the member administrations large taxpayers percentage ratio compared

to the general amount of the taxpayers is between 1% -2% (those five countries are:
Albania, Austria, Finland, Ireland and the Netherlands). All of those five countries
consider a “Group” of related companies (including mother companies and
subsidiaries) as one large taxpayer.

14% of the member administrations reported the percentage of large taxpayers

percentage ratio compared to the general number of the taxpayers between 2%-4%
(those four member tax administrations are Belgium, Croatia, France and Republic
of Srpska).

Only 8% of the member administrations large taxpayers show a percentage ratio of

4% or more between the number of large taxpayers and the whole taxpayer
community (Sweden and Denmark).

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

Ten member administrations have limited the number of large taxpayers according
to the limited resources of LTU. Nevertheless they acknowledge the importance of
a specific treatment of large taxpayers and plan to widen the service and control
tool of LTU.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

6. FURTHER INFORMATION

It is clear that, whilst there are common features of the structures of LTU, there
are also significant differences. It is also evident that the structures are evolving.
As a result of it the definitions of a large taxpayer are changing too.

The United Kingdom, for example, has recently implemented a single large taxpayer unit
to replace its previous units that dealt separately with direct taxes and indirect taxes,
Customs and Excises. Large Business Service (LBS) was formed when the Inland Revenue
and HM Customs & Excise departments merged to become HM Revenue & Customs in April
2005, from the various large business units of these departments. It is reviewing its
existing policies and definitions of a large business in order to main a consistent approach
across the taxes now administered by HMRC.

Another example is that of the Belgian LTU, which is planning to extend its scope from
dealing only with financial services and extremely large companies and groups to cover
more large cases, enabled by an increase of staff from about 40 to about 850. At the
moment, the Belgian Tax Administration does not have a specific definition for the term
large taxpayer; there is no legal definition or guidance at all.

By today the administration has only a number of units responsible for the audit of the
financial sector (banks, insurance companies, holdings, companies listed at the stock
exchange, etc.) and the construction industry.

The head of the administration dealing with large taxpayers, which has to be created, has
already been appointed and can rely on a small number of staff. A proposition of the
criteria to be used in defining large taxpayer, addressed to the Policy Board of the Federal
Public Service Finance has been made but at the moment, a final decision has not been
taken yet.

The Irish Large Case Division, as another example, is currently under reviewing procedure.
The review points to a number of issues, including the case base (size, coherence of case
base for a Large Case Programme, and systems for entry/exit of cases to/from Large Cases
Division) and an analysis of whether there is sufficient staff to undertake the work, current
and planned.

The Irish Revenue structure is designed around its customer base. This structure was put in
place in 2003 when a detailed set of “case allocation rules” was developed and
implemented. There are four Regional Divisions with each Region responsible for all of the
taxes and duties of customers within their geographical area except for certain large cases
(350 large legal entities and 2,360 wealthy individuals) dealt with by the Large Case
Division.

The definition of Large Taxpayers is a very new one in Austria; as it has come in force on
the 1st of January 2007. In an ongoing project about the reorganization for Auditing Large
Taxpayers the criteria will be discussed.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

Finland has also renewed the definition for large taxpayer in 2007. As a result of this
change in the law all the banks and insurance companies, all listed companies and all
European companies (Societas Europaea) will be clients of the Tax Office for Large
Taxpayers from the beginning of the year 2008. Earlier only groups of companies or single
companies having turnover more than EUR 50 million were clients of the Finnish LTU.
Based on those measures the number of cases doubled and the office got also some extra
resources. Experiences from the first ten years time since establishing the office 1998
showed that a wider client base was needed. It was also a part of a reorganization work in
the whole administration still going on in Finland.

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 IOTA Report for Tax Administrations – Definition of ‘Large Taxpayer’

7. LIST OF ANNEXES

• Questionnaire form used for the survey attached as Annex I.

• Details on criteria used are compiled in Annex II.
• Details on given factors used are compiled in Annex III.
• Details on values used are compiled in Annex IV.
• More information on large taxpayer is compiled in Annex V.

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 Before making entries please read the
attached letter!!!

HOW TO DEFINE A LARGE TAXPAYER

QUESTIONNAIRE

Each Member of the “Large Taxpayer Treatment and Audit”

Area Group is requested to complete and return this
Questionnaire by not later than 10 August 2007 to
TechnicalActivities@iota.hu

QUESTIONS

1. IOTA Member Country:

(Full Member) ………………………….

(Associate Member) ………………………….

2. Do you have a definition for the term Large Taxpayer?

Legal Definition

Guidance or Other

No
2a. Please provide the Definition:

3. What criteria do you use to define a Large Taxpayer?

Turnover level (please provide details)

Number of employees (please provide details)

Profit level (please provide details)

Amount of paid taxes (please provide details)

Value of assets (please provide details)

Others (please provide details)

3a. What further factors are used to determine whether the

taxpayer is a large one?

Legal status
Individuals
Only limited companies
Other
 Multi national companies
Group of connected companies have been
treated as one large taxpayer (please provide
details)

Large taxpayer are identified by branch or

sector (please provide details)

Stock exchange Company

4. How often do you update the list of your large taxpayer?

Every year
Every two year
Other (provide number)

5. How long are they treated as a large taxpayer even if they

don’t meet the criteria?

One year
Two year
Other (provide number)

6. How many registered large taxpayers do you have in your

country?
 What is the percentage of large taxpayers compared to the
total number of taxpayers?

6a. Do you have a limited number of large taxpayers that your

large taxpayer unit can handle?

Yes (provide number and why)

No

7. Extra Information:

ABOUT YOU

Name ………………………………………………………………………………
Title/position ………………………………………………………………………………
Organisation ………………………………………………………………………………
Country ………………………………………………………………………………
e-mail ………………………………………………………………………………
Thank you !!!
 Yes No Criteria used to determine Large Taxpayer
L=Legal Turnover Number of Profit Amount of Value of Others
O=Other level employees level paid taxes assets
Albania L X X
Austria O X X
Azerbaijan
Belgium (not officiel) L (project) X X X X
Bosnia & Herzegovina
Bulgaria L X X X X
Croatia L X X X X X
Cyprus
Czech Republic O X
Denmark O X X X
Estonia O X X X
Finland L X X
France O X X
Fyr Macedonia
Georgia
Germany O X X X X
Greece X X
Hungary L X X
Iceland
Ireland L X X X X X X
Italy O X X
Latvia O X X X X X
Lithuania O X
Malta X
Moldova
Montenegro
Netherlands O X X
Norway O X X X
Poland
Rep. of Srpska L X
Romania L X X
Serbia L X
Slovakia L X
Slovenia L X X
Spain L X
Sweden O X
Switzerland X
Ukraina
United Kingdom O X
3 22 9 2 7 5 19
 Given Factors used to determine Large Taxpayer
Yes Factor
L=Legal Legal Individuals Limited Others Multi national Group of con- branch name of Stock exchange
O=Other Status Companies companies nected companies o sector branches companies
Albania L X X X X X X bank, insurance, etc. X
Austria X X bank, insurance, etc.
Azerbaijan
Belgium (not officiel) L (project) X X X X X financial sector X
Bosnia & Herzegovina
Bulgaria L X X bank, insurance, etc.
Croatia L X bank, insurance, etc.
Cyprus
Czech Republic O X X bank X
Denmark O X X X X bank, insurance, etc.
Estonia O X X bank, insurance X
Finland L X X X X X bank, insurance X
France O X X X X bank, insurance, etc.
Fyr Macedonia
Georgia
Germany O X X
Greece X
Hungary L X bank, insurance
Iceland
Ireland L X
Italy O X bank, insurance X
Latvia O X X bank, insurance, etc.
Lithuania O X bank, insurance
Malta
Moldova
Montenegro
Netherlands O X X X bank, insurance, etc. X
Norway O X X bank, insurance
Poland
Rep. of Srpska L X bank, insurance, etc.
Romania L X X X bank, insurance X
Serbia L X
Slovakia L X bank, insurance, etc.
Slovenia L
Spain L
Sweden O X X financial companies X
Switzerland X X X bank, insurance, etc. X
Ukraina
United Kingdom
8 3 6 3 7 10 21 10
 Yes No Values of the used criteria (Euro)
L=Legal Turnover Number of Profit Amount of Value of
O=Other Level employees level paid taxes assets
Albania L 1,220,000
Austria O 4,000,000 100
Azerbaijan
Belgium (not officiel) L (project) Large companies 7,300,000 50 or 100 3,650,000
Large associations 6,250,000 50 or 100 3,125,000
Bosnia & Herzegovina
Bulgaria L 5,000,000 750 1,000,000
Croatia L 30,000,000 250 6,900,000 15,000,000
Cyprus
Czech Republic O 37,000,000
Denmark O 400,000,000 250
Estonia O 31,000,000 125
Finland L 50,000,000
France (DVNI) O Selling 152,400,000 400,000,000
France (DGE) O Service 76,200,000
Fyr Macedonia
Georgia
Germany O 3'700'000 to 26'500'000 105000 to 500'000
Greece X 9,000,000
Hungary L 8,800,000
Iceland
Ireland L Corporate groups 130,000,000 13,000,000 50,000,000
Italy O 25,822,845
Latvia O 3,415,000 250 285,000 142,000
Lithuania O 14,500,000
Malta X
Moldova
Montenegro
Netherlands O 12,500,000
Norway O
Poland
Rep. of Srpska L 3,000,000
Romania L
Serbia 1,200,000
Slovakia L 29,561,310
Slovenia L 33,000,000
Spain L 6,010,121
Sweden L
Switzerland X
Ukraina
United Kingdom
 Update list of LT after when they s how many LT % of LT Limited
Every Every two Other one two Other comp. To number of
year year year year year all Taxpayer LT
Albania X X 1,055 1.70% Yes 500
Austria X X 16,828 1.64% No
Azerbaijan
Belgium (not officiel) X X 12,000 3.16%
Bosnia & Herzegovina
Bulgaria X X 683 0.04% No
Croatia X X 2,111 3.50% Yes 150
Cyprus
Czech Republic X 3 1,042 0.57% No
Denmark X X 2,530 6% No
Estonia X X 497 0.82% No
Finland 3 X 4,400 1.50% Yes
France immediately X 66'000 tax audit VAT 1% (dge) 1.89% (dvni)
35'000 tax management 1.75 % (dge) 3.3% (dvni)
Fyr Macedonia
Georgia
Germany 3 3 179,765 0.56% No
Greece 4 X 3,034 0.33% Yes
Hungary X 3 610 0.005% Yes
Iceland
Ireland X X X X 1,600 1.50% Yes
Italy X X 12,000 0.01% No
Latvia X 314 0.22% No
Lithuania X X X 258 0.15% No
Malta
Moldova
Montenegro
Netherlands X X 1,275 1.10% Yes
Norway X X 3,000 0.70% Yes
Poland
Rep. of Srpska X 696 1.26% - 3.62% No
Romania X X 950 0.0007% No
Serbia X X 348 0.22% legal entities Yes 500
Slovakia X X 554 0.08% No
Slovenia X 444 0.42% No
Spain X X 38,026 0.80% No
Sweden X X 15,000 less 5% Yes 15,000
Switzerland X 45 less 0.1% No
Ukraina
United Kingdom X 3 2,500 less 1% No