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Raoul Stocker |
Yan Hurdowar |
On March 22 2016, the OECD published its standardised electronic format for the exchange of country-by-country (CbC) reports between Competent Authorities.
The publication includes a CbC extensible markup language (XML) schema and related User Guide. Both documents were developed to facilitate the swift and uniform implementation of CbC reporting (CbCR) and with a view to accommodating the electronic preparation, filing and exchange of CbC reports.
A common electronic format for the automatic exchange of information was expected, as the OECD already indicated in the final report on Action 13 that it intended to develop a standardised mechanism for the exchange of CbC reports.
The CbC XML Schema has been primarily designed to be used for the automatic exchange of CbC reports between Competent Authorities. However, the CbC XML Schema can also be relied upon by reporting entities for transmitting the CbC report to their tax authorities, provided the use of the CbC XML Schema is mandated domestically.
Swiss perspective
Switzerland is expected to introduce the CbCR requirement in 2017 requiring Swiss multinational enterprises (MNEs) to provide the first report in 2018. As such, the exchange of CbC reports will start no later than 18 months after the last day of 2017. However, multiple countries have already confirmed that they require the filing of CbC reports by MNEs by December 31 2017 (that is, one year earlier). Therefore, Swiss-based MNEs with foreign operations should be aware that local tax authorities might require the use of the CbC XML Schema sooner than expected.
In this respect, Swiss companies should consider whether their IT systems would be compatible with an XML reporting standard as it can be expected that local tax authorities will rely on the taxpayer to prepare the CbC XML Schema.
Raoul Stocker (rstocker@deloitte.ch) and Yan Hurdowar (yhurdowar@deloitte.ch)
Deloitte
Tel: +41 58 279 6271 and +41 58 279 8152
