On 18 May 2018, the Swedish tax authority issued guidelines, clarifying its use of country-by-country (CbC) report information. The guidelines are in line with the OECD guidelines on the appropriate use of information included in CbC reports that were issued on 6 September 2017.
Accordingly, the Swedish Tax Agency has published guidance whereby the following use of CbC report information is explicitly allowed:
- Overall analysis of transfer pricing risks and other risks of tax base erosion;
- Selection of companies for further audits; and
- Economic and statistical analysis, where appropriate.
The OECD guidance notes that where a tax authority proposes tax adjustments based solely on information contained in a CbC report, there is a significant risk that these adjustments will be based on inaccurate assumptions. This could result in an incorrect tax assessment being issued, and possibly double taxation.
