The Swedish Tax Agency has submitted its proposal to the Swedish Ministry of Finance regarding the implementation of BEPS action 13 about documentation and sharing of country-by-country reports (CbC).
The Swedish Tax Agency was previously instructed by the Swedish Ministry of Finance to complete draft legislation for the implementation of the revised standards for transfer pricing documentation following the completion of BEPS Action 13 by the OECD.
On 29 April 2016 the Swedish Tax Agency submitted its proposal to the Ministry of Finance covering the new OECD standard for transfer pricing documentation and the automatic exchange of country-by-country (CbC) reports. The proposal also included provisions for the exchange of CbC reports between countries, including the EU Directive for the automatic exchange between EU members (DAC 4) and the OECD multilateral agreement on CbC reporting.
The Swedish Tax Agency's proposal is summarized below:
Master File and Local File
CbC reporting will relate to fiscal years starting on or after 1 January 2016 despite the fact that the legislation will likely be enacted this year. However, the updated transfer pricing documentation rules (Master File and Local File) are proposed to come into effect from 1 January 2017.
The Swedish Tax Agency has now submitted its proposal to the Ministry of Finance. It is likely that the Ministry of Finance will draft a bill based on the Swedish Tax Agency proposal and that it will passed into law in autumn 2016 (at the earliest).
Please feel free to contact us if you want more information about how this proposal might affect your company.
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