The OECD has released an XML Schema update for CbC reporting

News, 12/4/2020

Version 2.0 (Country-by-Country Reporting XML Schema 2.0) is now released by the OECD, replacing the previous 1.0 version. The new version of the XML Schema will go into effect in early 2021 and it concerns the reports relating to the international exchange of tax information. Version 2.0 contains a number of structure updates for the XML file.

The introduction of the 2.0 version causes some changes to the fields of the electronic form in Lomake.fi. If you submit CbC reports in Lomake.fi, please take account of the changes and fill the fields in accordingly. No other action on your part is required. In early 2021, the Tax Administration will release its updated fillable web form for the CbC report for completion in Lomake.fi.

If you submit CbC reports via the Ilmoitin.fi gateway and create your own files in the XML format, you must make the version 2.0 adjustments yourself. The changes and updates include:

  • A new procedure for making corrections was introduced. You can no longer file a replacement report to remedy an error.
  • The Schema “version” attribute is now a required attribute.
  • The new StartDate and EndDate elements in the Reporting Entity/Reporting Period structure are now required.
  • The ReportingEntity structure is required when you remedy any errors, as well.
  • Changes were made to the types and lengths of elements in order to match the reporting Schema in the exchange of information.
    • This means that you can no leave any elements blank when you submit a report (with some exceptions). For example, if your previous practice was to not fill in the data element for “floor number in the building”, i.e. <cbc:FloorIdentifier></cbc:FloorIdentifier>, you can no longer do so. Instead, delete the element if you have no floor number to report.
  • The start date of the fiscal year does not have to be stated inside the Warning element.
  • The ReportingEntity structure now contains an optional NameMNEGroup element.
  • The ConstEntities structure now has a new Role element, which also is optional.
  • The AdditionalInfo structure contains the OtherInfo element. This element now has the optional ‘Language’ attribute.

The Tax Administration has updated its CbC reporting guidance accordingly. An updated Technical Guidance has been released, containing instructions for the files in the XML format, to be compliant with the 2.0 version. If you submit your report through Ilmoitin.fi, you can start using the version 2.0 XML Schema as of 26 January 2021. After that date, no submittals for any taxable years can no longer be sent in accordance with the previous 1.0 version.

However, the Country-by-Country Report for 2019 must be filed as a file compliant to version 1.0 of the Schema. In the same way, if you need to make corrections relating to your 2019 CbC report, or for earlier years, you must implement version 1.0 of the Schema up to 25 January 2021. After that date, corrections must be made in accordance with the 2.0 version.

Date of CbC report submittal The XML schema in effect The Technical Guidance
25 Jan 2021 or before 1.0 Version 1.8 Version
26 Jan 2021 or later 2.0 Version 1.9 Version

We urge the Finnish corporations that are required to submit CbC reports to be prepared for the migration to the new Schema. The updated guidance will concern all CbC reporting and all corrections to it, for all years, starting 26 January.

Any questions about the Schema update? You can send your questions and contact requests to siirtohinnoittelu(a)vero.fi, our e-mail address.

Technical guidance and XML example files