Under the new legislation the Swedish Transfer Pricing Documentation regulations are adapted to the OECD’s new standard which was presented in BEPS Action 13 Final Report. For more information on what the new legislation entails for Swedish taxpayers, see TaxNews no 4, 2017.

The Swedish Tax Agency (STA) has now published information on how Swedish companies are to submit notifications to the STA of which group entity will submit the Country-by-Country Report as well as how the Country-by-Country Report is to be submitted in Sweden.

Notifications to STA of which group entity will submit the Country-by-Country Report

The notification shall be submitted to the STA by April 30, 2017 at the latest for financial years which have concluded before April 1, 2017. Going forward the notification shall be submitted to the STA by the last day of the financial year at the latest. The notification is a requirement for all Swedish companies and permanent establishments which are part of a group which is obliged to prepare a Country-by-Country Report.

The information which is to be included and submitted to the STA is the following:

• Name and identification number of the Swedish entity which is submitting the notification,
• Name, address and identification number of the Swedish or foreign entity which is obliged to submitted the Country-by-Country Report, 
• In which country the entity which will submit the Country-by-Country Report is resident, and
• The dates which the relevant financial year to which the Country-by-Country Report pertains begins and ends.
   

The notification is to be sent to:

Skatteverket
403 32 Göteborg
Sweden

For more information, see the STA’s website (page only available in Swedish). 

Submission of the Country-by-Country Report in Sweden

The Country-by-Country Report is to be submitted in Sweden by December 31, 2017 at the latest for the financial year January 1 to December 31, 2016. For companies with a split financial year, the Country-by-Country Report shall be submitted within 12 months after the end of the financial year. Under the legislation, multinational groups which in the year preceding the financial year have reported revenues exceeding SEK 7 billion shall submit details every year for each tax jurisdiction in which they are active.

Swedish companies which are to submit Country-by-Country Reports to the STA in the electronic XML-format. The STA will publish a technical description for Country-by-Country Reports which describe their form as well as how the files are to be submitted to the STA. Information on the XML for Country-by-Country Reports is also available in the OECD’s CbCR User Guide.

KPMG’s comments

The Swedish requirements for Country-by-Country Reporting will, as anticipated, apply as of the financial year 2016. Therefore it is important that groups which fulfill the requirements for Country-by-Country Reporting prepare for this reporting obligation.

N.B. the notification to the STA shall be submitted manually and sent to the STA by April 30, 2017 at the latest for financial years which are concluded before April 1, 2017. Each Swedish entity which is part of a group within the scope of Country-by-Country Reporting must submit a written notification to the STA on its own behalf.

As the regulations on the form of the XML for Country-by-Country Reporting are currently unclear, we welcome the technical description which the STA has stated that they will publish.

Please feel free to contact us if you would like to know more about the notification process or Country-by-Country Reporting.

Annika Lindström
annika.lindstrom@kpmg.se

Karolina Viberg
karolina.viberg@kpmg.se