Proposals for the implementation of country-by-country transfer pricing reporting have been submitted to Sweden’s Council on Legislation alongside a draft law to transpose the updated EU Directive on administrative cooperation. According to an October 20 announcement by the Ministry of Finance, the legislation provides not only for the introduction of CbC reporting in Sweden, but also for the automatic exchange of CbC reports between the competent authorities of jurisdictions that have signed the OECD’s Multilateral Competent Authority Agreement for the automatic exchange of CbC reports.
It is proposed that CbC reports be submitted by multinational corporations with sales exceeding SEK7bn (USD785m) and contain information on royalty income, earnings before income tax, the number of employees, share capital, retained earnings, and tangible assets for each tax jurisdiction in which they are operating.
These requirements would cover foreign legal persons having a permanent establishment in Sweden as well as Swedish companies with permanent establishments abroad. It is also proposed that the legislative proposals enter into force on April 1, 2017.
