On 4 December 2020, the Finnish tax authority has updated its CbC reporting guidance concerning changes in the Country-by-Country (CbC) reporting XML schema to Version 2.0.

Version 2.0 (Country-by-Country Reporting XML Schema 2.0) is 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 tax authority also released updated Technical Guidance containing instructions for the files in the XML format, to be compliant with the 2.0 version.

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.

If user submit their report through Ilmoitin.fi, they 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 user need to make corrections relating to your 2019 CbC report, or for earlier years, they 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.