In case your group or client has updated Country-by-Country Reporting (CbCR) information, a CbCR correction should be made. A reason for making a correction could be for example due to changes in the financial figures (Table 1), entity details (Table 2) or updates in comments (Table 3) resulting from mandatory corrections or errors in the previous provided information.
The OECD advices to start exchanging the CbCR filings no later than 18 months after the last day of the that fiscal year (reference to section 3 of the “MULTILATERAL COMPETENT AUTHORITY AGREEMENT ON THE EXCHANGE OF COUNTRY-BY-COUNTRY REPORTS”). It is therefore advisable that corrections also should be made within this period.
Technical complications creating CbCR correction
The OECD has a complex correction system where multiple “corrections” can be made. A Country-by-Country Reporting (CbCR) correction can be made after an initial filing is done. In most cases, CbCR corrections refer to previous filings and/or “corrections”. The system uses reference IDs in such way a “correction” refers to a previous filing. The OECD system is limited in such, that additions of data and updates of data cannot be sent in the same file. Therefore, if you want to add and update data, you will need to send two files to the tax authorities. A confusing side issue here is that addition of entities to present CbCR jurisdictions, this is seen as an “update” of the data instead of addition of data, due to the fact that the country-related details are “updated”.
Many countries have interpreted the OECD specifications their manner when developing their CbCR systems. In some countries (i.e. The Netherlands) corrections can only be made by doing a full refiling, including the initial (correct) data. Other countries deviate from the OECD specifications so that the corrected parts need to be submitted with limited references to earlier uploads (i.e.Switzerland) and other countries follow exactly the OECD guidelines (such as United Arab Emirates).
Additionally, many countries use their own internal reference ID format: A complex combination of characters identifying different parts in the CbCR XML.
Luckily, you do not have to bother with these country-specific implementations when using TPGenie. Depending on your CbCR Jurisdiction TPGenie generates the corrections and files according to the specifications of the country.
In case of only updated or added data, the system generates a corrected file. In case of both an update and added data, we need two correction files according to the OECD specifications: One file for adding the new CbC data and one file for the corrections on existing CbC data.
To learn more about our CbCR tool and it’s correction features, you can click the below button.
OECD “MULTILATERAL COMPETENT AUTHORITY AGREEMENT ON THE EXCHANGE OF COUNTRY-BY-COUNTRY REPORTS”:
For up-to-date information on the signatories of the agreement to exchange CbC reports please find the link below:
For up-to-date additional details and requirements relating to the CbCR filings please find the following link below: