The Swedish Tax Agency (STA) has proposed to implement transfer pricing documentation and Country-by-Country (CbC) Reporting. As per the proposal, the Master File reporting obligations will be applicable to MNEs that have more than 250 employees and minimum consolidated revenue of SEK 450 million or having a minimum consolidated balance sheet total of SEK 400 million in FY 2017. The content of the master file is consistent with OECD BEPS Action 13 recommendations and will be effective from 1 January 2017.
The local file reporting obligations will be applicable to MNEs that have more than 250 employees and minimum consolidated revenue of SEK 450 million or having a minimum consolidated balance sheet total of SEK 400 million in FY 2017. The content of the local file is consistent with OECD BEPS Action 13 recommendations and will be effective from 1 January 2017.
Under the current proposal, Multinational Enterprises (“MNE”) with a minimum consolidated revenue of SEK 7 billion (equivalent to EUR 750 million) in FY 2016 will be required to submit a CbC report with the Swedish Tax Agency within one year from the end of the fiscal year. CbC reporting would concern fiscal years starting on or after 1 January 2016 (i.e., retroactively for 2016).
