Sweden: Proposed legislation, transfer pricing documentation and country-by-country reporting

Sweden: Transfer pricing documentation, CbC reporting

The Swedish tax agency in late April 2016 submitted to the Swedish Ministry of Finance a proposal for legislation to implement recommendations under Action 13 of the base erosion and profit shifting (BEPS) project with respect to transfer pricing documentation and the rules for the automatic exchange of country-by-country (CbC) reports.

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The proposed legislation also includes provisions for the exchange of CbC reports between countries—including the EU Directive for the automatic exchange between EU members (known as ”DAC 4”) and the OECD multilateral agreement on CbC reporting.

The Swedish tax agency’s proposed legislation includes measures for Master file and Local file documentation as well as CbC reports. As proposed, the CbC reporting would concern fiscal years starting on or after 1 January 2016 (i.e., retroactively for 2016). However, the updated transfer pricing documentation rules (concerning the Master file and Local file measures) are proposed to be effective 1 January 2017.


Read a May 2016 report prepared by the KPMG member firm in Sweden

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