Can companies report at a centralized level if subsidiaries in different Member States have different Economic Operators Registration and Identification (EORI) numbers?
Yes, companies have options for centralized reporting despite variations in subsidiary EORI numbers:
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Separate Reporting by Subsidiaries:
- By default, CBAM goods are associated with a CBAM reporting declarant via the EORI number provided to customs authorities. Consequently, subsidiaries with distinct EORI numbers typically file CBAM reports separately.
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Centralized Reporting via Indirect Customs Representative:
- Multinational corporations can appoint a single indirect customs representative to fulfill customs and CBAM obligations at a centralized level for multiple group entities. This streamlines reporting processes across subsidiaries.
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Group Entity as Indirect Customs Representative:
- One group entity may act as the indirect customs representative for CBAM goods imported by all other group entities. However, the appointed indirect customs representative must execute customs obligations and submit CBAM reports accordingly.
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Service Provider for CBAM Reporting:
- A group entity can offer CBAM reporting services to other subsidiaries within the multinational corporation. While feasible, each importing entity remains the reporting declarant for goods they import, retaining legal liability for CBAM reports. Additionally, the service provider must submit separate CBAM reports for goods imported by each entity, including those imported by itself.
Dubrink’s CBAM compliance software facilitates centralized reporting by streamlining data aggregation and submission processes across subsidiaries, ensuring efficient and accurate compliance with CBAM regulations.