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- » Country-by-country reports (CbCR) and notifications regarding such reports
Country-by-Country Reporting and Notifications
Under the provisions of DAC 4 and BEPS Action 13 on Country-by-Country Reporting, Sweden annually exchanges CbC Reports with our partner jurisdictions. These rules are incorporated in Swedish legislation through Chapter 33 a of the Swedish Tax Procedure Act.
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The requirement to submit Country-by-Country Reporting in Sweden applies to multinational groups with an annual global turnover of at least SEK 7 billion.
According to the main rule, the ultimate parent entity (UPE) of a group files a Country-by-Country Report (CbC Report) for the entire group in its residence jurisdiction. A Swedish entity being a UPE of a group covered by the reporting requirement, files the group’s Country-by-Country Report to the Swedish Tax Agency.
In certain circumstances, other Swedish entities are also required to file a CbC Report to the Swedish Tax Agency, Chapter 33 a, Section 5 of the Tax Procedure Act (2011:1244). This requirement occurs when
- the group UPE does not have an obligation to submit such a report in its residence jurisdiction,
- the residence jurisdiction does not have a valid exchange agreement with Sweden, or
- the Swedish Tax Agency has notified the Swedish entity that there will not be an exchange of CbC Reports with the Ultimate Parent Entity’s residence jurisdiction.
When to submit a Country-by-Country Report to the Swedish Tax Agency?
The Country-by-Country Report must be received by the Swedish Tax Agency no later than 12 months following the end of the financial year.
If you have questions
Please send any general, legal or technical questions concerning Country-by-Country Reporting to CbC-rapportering@skatteverket.se
OECD changes the XML Schema for CbC Report Exchanges on 31 January 2021
The Swedish Tax Agency now accepts Country-by-Country Reports from Swedish multinational groups only in version 2.0 of the XML schema.
All reports which the Tax Agency transfers to, or receives from other countries as of 1 February 2021 will have been filed by the reporting multinational group in version 2.0 of the XML schema.
Updated information concerning upcoming change of XML Schema
Important dates:
- Reports in version 1.0.1 can be filed until 31 October 2020
- Reports and corrections filed on 1 November 2020, or later must be filed in version 2.0
- The File Transfer Service will be temporarily closed in November 2020
- The Swedish Tax Agency plans to open the File Transfer Service for version 2.0 on 1 December 2020
- A new Example XML file and test service according to the updated XML Schema will be available when the File Transfer Service opens for version 2.0
User Guide
Links to the new Swedish User Guide for version 2.0 and a compilation of the most significant changes and added elements (not exhaustive) are posted below. We refer to the OECD User Guide for an exhaustive description of the changes.
User Guide for filing of Country-by-Country Reports, version 4.0 (information in Swedish)
OECD User Guide for Tax Administrations Version 2.0 (June 2019)
Compilation of the most significant changes and added elements (not exhaustive)
Notification
Notifications by ultimate/surrogate parent entities and other entities submitting CbC Reports
All Swedish Entities that are part of a group required to file a Country-by-Country Report in Sweden, or in another jurisdiction, must notify the Swedish Tax Agency annually. A Swedish entity is an entity which is subject to unlimited tax liability in Sweden, Swedish partnerships (Swedish: handelsbolag), and the permanent establishments of foreign entities in Sweden.
If there are multiple Swedish entities in the group which are required to file a Country-by-Country Report, the group can appoint any one of them to submit the report as a surrogate parent entity. If the group fails to appoint a surrogate parent entity, all Swedish entities are required to submit a CbC Report.
If you represent a Swedish entity, which is submitting a CbC Report, you are required to notify the Swedish Tax Agency before the end of the financial year that is to be reported.
The notification is to be submitted on form SKV 2381.
Please use this form to notify (information in Swedish):
Notification concerning the reporting requirement of another entity
If you are part of a group and another entity will file a CbC Report on behalf of the entire group, you must notify the Swedish Tax Agency before the end of the financial year to be reported. This applies regardless in which jurisdiction the other entity will submit the report.
Please use this form to notify:
Electronic filing of a Country-by-Country Report
User Guide
In the Swedish Tax Agency’s User Guide SKV260-CbCR (Swedish: Teknisk beskrivning), you will find help in order to assemble the XML file for CbC Reporting. The User Guide provides information on the XML format and describes how to deliver the file. Additional information regarding XML for CbC Reporting is available in the OECD Country-by-Country Reporting: XML Schema User Guide for Tax Administrations (Version 2.0 published June 2019). Some additional information is also available in EU regulations (DAC 4).
Reporting Swedish entities are to use the CbC XML 2.0 version beginning December 1, 2020. Please also refer to the Swedish User Guide 4.0 linked below.
Electronic filing of XML version 2.0 on this website will be available by December 1, 2020. Please be informed that the File Transfer Service will be temporarily closed during November 2020.
Example File and Test Service
The Swedish Tax Agency has developed a simple Example XML File that can be opened and viewed in an XML editor, text editor or similar program. From a practical standpoint, it is not possible by guidance of the Example XML File to convert data to an XML file using for example MS. Excel. The file can, however, be used to gain understanding on how the format and schema are supposed to work.
It is also possible to run the file through the Tax Agency’s test service. The example file has been updated to the OECD schema version 2.0.
The Tax Agency’s test service can be used for testing of CbC Reporting XML files, in order to check that they validate correctly. The test service will be updated for the 2.0 XML schema version later in November 2020.
Please note that the Swedish Tax Agency does not offer a solution for building XML files or supply recommendations of which solutions or vendors that might be appropriate.
Example file XML version 1.0.1:
Example file XML version 2.0:
To the Test Service:
E-Service
File an XML report electronically through the e-service Lämna filer – CRS och FATCA samt CbCR at this website. You need to log in using e-identification to be able to access the service. Bank-id, Mobilt bank-id, Freja eID+, Telia and AB Svenska Pass issue valid e-identifications. The following countries, which have all joined the eIDAS cooperation, issue accepted foreign e-identifications: Belgium, Estonia, Italy, Croatia, Luxembourg, Portugal, Spain, United Kingdom and Germany.
Lämna filer - CRS och FATCA samt CbCR
Notification that a Country-by-Country Report is incomplete
If a Swedish entity, being neither the Ultimate Parent Entity nor the Surrogate Parent Entity is obliged to submit a CbC Report, the report may be incomplete. This applies in case the Ultimate Parent Entity refuses to supply the information needed to complete the report.
Swedish entities filing an incomplete report due to the Ultimate Parent Entity refusing to supply necessary information are to notify the Swedish Tax Agency regarding this issue. This is done in connection with the filing of the CbC Report in the file transfer service.
Swedish Ultimate Parent Entities and Swedish Surrogate Parent Entities are obligated to file complete reports. If such an entity does not file a complete report, no report will be considered as received.
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