Action 13 of the OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) requires the development of “rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into consideration the compliance costs for business. The rules to be developed will include a requirement that MNEs provide all relevant governments with needed information on their global allocation of the income, economic activity and taxes paid among countries according to a common template”.
In response to this requirement, a three-tiered standardised approach to transfer pricing documentation has been developed, including the requirement for MNEs with annual consolidated group revenue equal or exceeding EUR 750 million (or an approximately equivalent amount in domestic currency) to file a Country-by-Country (CbC) Report that will provide annually and for each Tax Jurisdiction in which they do business the amount of revenue, profit before income tax and income tax paid and accrued. It also requires MNEs to report their number of employees, stated capital, accumulated earnings and tangible assets in each Tax Jurisdiction. Finally, it requires MNEs to identify each entity within the group doing business in a particular Tax Jurisdiction and to provide an indication of the business activities each Constituent Entity engages in.
CbC Reports should be filed in the Tax Jurisdiction of the Reporting Entity and shared between jurisdictions through automatic exchange of information, pursuant to government- to-government mechanisms such as the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, Double Tax Conventions or Tax Information Exchange Agreements (TIEAs). In limited circumstances, secondary mechanisms, including local filing can be used as a backup.
In order to facilitate the swift and uniform implementation of CbC Reporting and with a view to accommodating the electronic preparation, filing and exchange of CbC Reports, the present CbC XML Schema and the related User Guide have been developed.
A schema is a data structure for electronically holding and transmitting information. XML, “extensible markup language”, is commonly used for this purpose. Examples are the OECD’s Common Reporting Standard XML Schema, the United States’ FATCA XML Schema and the European Union’s Fisc 153 format.
This User Guide explains the information required to be included in each CbC data element to be reported in the CbC XML Schema v. 2.0. It also contains guidance on how to make corrections of data items within a file that can be processed automatically.
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How the CbC User Guide links to the CbC XML Schema
This User Guide is divided into logical sections based on the schema and provides information on specific data elements and any attributes that describe that data element.
The Country-by-Country Reporting XML Schema Information sections are:
- Message Header with the sender, recipient, message type, reporting period
- The identifying information to be provided for each Constituent Entity
- The body of the CbC XML Schema, containing the reportable information on the Reporting Entity and each Constituent Entity, as well as a summary of the activities of the MNE Group, as set out in the CbC reporting template.
The CbC XML Schema is designed to be used for the automatic exchange of CbC Reports between Competent Authorities. In addition, the CbC XML Schema may also be used for domestic reporting by Reporting Entities to their domestic tax authorities. Items relevant for domestic reporting only are shown in [brackets].
The requirement field for each data element and its attribute indicates whether the element is validation or optional in the CbC XML Schema.
“Validation” elements MUST be present for ALL data records in a file and an automated validation check can be undertaken. The sender should do a technical check of the data file content using XML tools to make sure all validation elements are present and, if they are not, a correction to the file should be made. The receiver may also check the presence of all validation elements and may reject the file in case such elements are missing. Some elements are shown as “(Optional) Mandatory”, indicating they are in principle required for CbC reporting, but only in certain instances, as further specified for the respective elements in this User Guide. Consequently, (Optional) Mandatory elements may be present in most (but not all) circumstances, so there cannot be a simple IT validation process to check these. For example, the Reporting Entity and CbC Reports elements are labelled as “Optional (Mandatory)”, indicating that both elements are in principle mandatory, unless one of the elements is left blank in the context of a correction of the other element (see the Corrections section below for further detail). Other “Optional” elements are, while recommended, not required to be provided and may in certain instances represent a choice between one type or another, where one of them must be used (e.g. choice between address fix or address free).
Sections V and VI of the CbC User Guide contain further guidance on the schema version and transliteration of information, respectively.
CbC XML Schema Information
I Message Header
Information in the message header identifies the Competent Authority that is sending the message, as well as the Competent Authorities receiving the message. It specifies when the message was created, what period (normally a fiscal year) the report is for, and the nature of the report (original, corrected, supplemental, etc.).
| Element | Attribute | Size | Input Type | Requirement |
| SendingEntityIN | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
[Although not used for exchanges between Competent Authorities in the context of CbC reporting, the Sending Entity IN element would be mandatory for domestic reporting and would identify the Reporting Entity reporting to the sending Competent Authority (e.g. by a domestic TIN or IN).]
| Element | Attribute | Size | Input Type | Requirement |
| TransmittingCountry | 2-character | iso:CountryCode_Type | Validation |
This data element identifies the jurisdiction of the Competent Authority transmitting the message. It uses the 2-character alphabetic country code and country name list based on the ISO 3166-1 Alpha 2 standard, complemented by the X5 code for stateless entities and income (The following disclaimer refers to all uses of the ISO country code list in the CbC XML Schema: For practical reasons, the list is based on the ISO 3166-1 country list. The use of this list does not imply the expression by the OECD of any opinion whatsoever concerning the legal status of the territories listed. Its content is without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area).
[For domestic reporting this element would be the domestic country code.]
| Element | Attribute | Size | Input Type | Requirement |
| ReceivingCountry | 2-character | iso:CountryCode_Type | Validation |
This data element identifies the jurisdiction(s) of the Competent Authority or Authorities that is(are) the intended recipient(s) of the message.
In the context of CbC reporting, all jurisdictions in which a Constituent Entity is found to be resident on the basis of the information provided by the Reporting Entity in the CbC Report should be entered in this field. It will be for the sending Competent Authority to make a determination as to which jurisdictions can actually receive the CbC Report for a given year, depending of the exchange relationships it has in effect for the purpose of
CbC reporting. The Receiving Country should be repeated only when the exact same information needs to be sent to more than one jurisdiction. [For domestic reporting this element would be the domestic country code.]
| Element | Attribute | Size | Input Type | Requirement |
| MessageType | cbc:MessageType_EnumType | Validation |
This data element specifies the type of message being sent. The only allowable entry in this field is “CBC”.
| Element | Attribute | Size | Input Type | Requirement |
| Language | iso:LanguageCode_Type | Optional (Mandatory) |
This data element specifies the language in which the content of the Additional Info element, if any, has been provided, by indicating the relevant language code pursuant to ISO 639 – Part 1 (ISO 639-1:2002). In accordance with the final report on BEPS Action 13, the language in which the CbC Report is to be submitted is determined by local law of the sending jurisdiction. With a view to allowing the most widespread use of the information contained in the CbC Report, the use of the English language is preferred, if permissible under such local law. See Section IV for further guidance on the transliteration of information.
| Element | Attribute | Size | Input Type | Requirement |
| Warning | 1 to 4’000 characters | stf:StringMin1Max4000_Type | Optional |
This data element is a free text field allowing input of specific cautionary instructions about use of the CbC message content.
| Element | Attribute | Size | Input Type | Requirement |
| Contact | 1 to 4’000 characters | stf:StringMin1Max4000_Type | Optional |
This data element is a free text field allowing input of specific contact information for the sender of the message (i.e. the sending Competent Authority [or the Reporting Entity in the context of domestic reporting]).
| Element | Attribute | Size | Input Type | Requirement |
| MessageRefID | 1 to 170 characters | stf:StringMin1Max170_Type | Validation |
This data element is a free text field capturing the sender’s unique message identifier (created by the sender) that identifies the particular message being sent. The identifier allows both the sender and receiver to identify the specific message later if questions or corrections arise. For exchanges of CbC Reports between Competent Authorities, the first part must be the country code of the jurisdiction of the sending Competent Authority, the second part the year to which the information relates, and the third part a unique identifier created by the sending jurisdiction.
[In case the CbC XML Schema is used for domestic reporting, the sending Reporting Entity should ensure that a unique identifier is created, which could be complemented by a Reporting Entity identification number, provided by the Competent Authority of the Tax Jurisdiction of the Reporting Entity.]
| Element | Attribute | Size | Input Type | Requirement |
| MessageTypeIndic | cbc:CbcMessageTypeIndic_EnumType | Validation | ||
This data element allows the sender to define the type of message sent. This element identifies whether data is new or corrected (see Guidance on the Correction Process below). Messages must contain all new or all corrected/deleted data, not a combination of both.
The possible values are:
- CBC401 = The message contains new information
- CBC402 = The message contains corrections/deletions for previously sent information
| Element | Attribute | Size | Input Type | Requirement |
| CorrMessageRefID | 1 to 170 characters | stf:StringMin1Max170_Type | Optional |
This data element is not used for CbC reporting.
| Element | Attribute | Size | Input Type | Requirement |
| ReportingPeriod | xsd:date | Validation |
This data element identifies the last day of the reporting period (i.e. the fiscal year of the MNE Group) to which the message relates in YYYY-MM-DD format. For example, if the fiscal year of the MNE Group runs from 1 April 2016 to 31 March 2017, the entry would be “2017-03-31”.
| Element | Attribute | Size | Input Type | Requirement |
| Timestamp | xsd:dateTime | Validation |
This data element identifies the date and time when the message was compiled. It is anticipated this element will be automatically populated by the host system. The format for use is YYYY-MM-DD’T’hh:mm:ss.nnn. Fractions of seconds may be used (in such a case the milliseconds will be provided in 3 digits, see “.nnn” in the format above). Examples: 2018-02-15T14:37:40 or 2018-02-15T14:37:40789 (with milliseconds)
II OrganisationParty_Type
This complex type is used to identify each of the Constituent Entities, including the Reporting Entity, on which information is to be provided as part of the CbC Report.
It comprises the following data elements:
| Element | Attribute | Size | Input Type | Requirement |
| ResCountryCode | 2-character | iso:CountryCode_Type | Validation |
Element Attribute Size Input Type Requirement
| TIN | 1 to 200 characters | cbc:TIN_Type | Validation | |
| Element | Attribute | Size | Input Type | Requirement |
| IN | 1 to 200 characters | cbc:OrganisationIN_Type | Optional |
| Element | Attribute | Size | Input Type | Requirement |
| Name | 1 to 200 characters | cbc:NameOrganisation_Type | Validation |
Element Attribute Size Input Type Requirement Address cbc:Address_Type Optional IIa. ResCountryCode
| Element | Attribute | Size | Input Type | Requirement |
| ResCountryCode | 2-character | iso:CountryCode_Type | Validation |
This data element should contain the country code(s) of the Tax Jurisdiction of the Constituent Entity (or, in case of a permanent establishment that is a Constituent Entity, the jurisdiction in which such permanent establishment is subject to tax).
IIb. TIN (TIN_Type)
| Element | Attribute | Size | Input Type | Requirement |
| TIN | 1 to 200 characters | cbc:TIN_Type | Validation |
This data element provides the tax identification number (TIN) used by the tax administration of the Tax Jurisdiction of the Constituent Entity. In case the relevant Constituent Entity has a TIN that is used by the tax administration in its Tax Jurisdiction, such TIN is to be mandatorily provided, as to ensure the quality of the data, as well as the correct use thereof. In case a Constituent Entity does not have a TIN, the value “NOTIN” should be entered.
| Element | Attribute | Size | Input Type | Requirement |
| TIN | issuedBy | 2-character | iso:CountryCode_Type | Optional (Mandatory) |
This attribute describes the jurisdiction that issued the TIN.
IIc. Entity IN (OrganisationIN_Type)
| Element | Attribute | Size | Input Type | Requirement |
| IN | 1 to 200 characters | cbc:OrganisationIN_Type | Optional |
This data element can be provided (and repeated) if there are other INs available, such as a company registration number or a Global Entity Identification Number (EIN).
| Element | Attribute | Size | Input Type | Requirement |
| IN | issuedBy | 2-character | iso:CountryCode_Type | Optional |
This attribute describes the jurisdiction that issued the IN. If the issuing jurisdiction is not known then this element may be left blank.
| Element | Attribute | Size | Input Type | Requirement |
| IN | INType | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
This attribute defines the type of IN being sent (e.g. EIN).
IId. Organisation Name
| Element | Attribute | Size | Input Type | Requirement |
| Name | 1 to 200 characters | cbc:NameOrganisation_Type | Validation |
This element should contain the full legal name of the Constituent Entity, including the domestic designation for the legal form, as indicated in its articles of incorporation or any similar document. In case the Constituent Entity is a permanent establishment, the name of the Constituent Entity should be followed by “(P.E.)”.
IIe. Address_Type
There are two alternative options for Address type in the CbC XML schema – AddressFix and AddressFree. In principle, AddressFix should be in all cases, unless the Reporting Entity is not in a position to define the various parts of a Constituent Entity’s address, in which case the AddressFree type may be used.
While the CbC reporting template does not require that the address of each Constituent Entity be reported, it is strongly recommended that this information is provided, as to ensure that the data in the CbC XML Schema is of a high quality, as to ensure that the data is accurately matched and appropriately used by the receiving jurisdiction(s).
This data element is the permanent residence address of a Constituent Entity.
| Element | Attribute | Size | Input Type | Requirement |
| CountryCode | 2-character | iso:CountryCode_Type | Validation |
This data element provides the country code associated with the Constituent Entity.
| Element | Attribute | Size | Input Type | Requirement |
| AddressFree | 1 to 4’000 characters | stf:StringMin1Max4000_Type | Optional |
This data element allows input of address information in free text. If the data is entered in “AddressFree”, all available address details shall be presented as one string of bytes, with blanks, slashes or carriage returns being used as a delimiter between parts of the address. This option should only be used if the data cannot be presented in the AddressFix format.
NOTE: If AddressFix is selected, there will be the option of inputting the full street address of a Constituent Entity in the AddressFree element rather than using the related fixed elements. In this case, the city, subentity, and postal code information should still be entered in the appropriate fixed elements.
| Element | Attribute | Size | Input Type | Requirement |
| AddressType | legalAddressType | stf:OECDLegalAddressType_EnumType | Optional | |
OECDLegalAddressType_EnumType
This is a datatype for an attribute to an address. It serves to indicate the legal character of that address (residential, business, etc.)
- OECD301 = residentialOrBusiness
- OECD302 = residential
- OECD303 = business
- OECD304 = registeredOffice
- OECD305 = unspecified
| Element | Attribute | Size | Input Type | Requirement |
| Street | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
Element Attribute Size Input Type Requirement
| BuildingIdentifier | 1 to 200 characters | stf:StringMin1Max200_Type | Optional | |
| Element | Attribute | Size | Input Type | Requirement |
| SuiteIdentifier | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
Element Attribute Size Input Type Requirement
| FloorIdentifier | 1 to 200 characters | stf:StringMin1Max200_Type | Optional | |
| Element | Attribute | Size | Input Type | Requirement |
| DistrictName | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
Element Attribute Size Input Type Requirement
| POB | 1 to 200 characters | stf:StringMin1Max200_Type | Optional | |
| Element | Attribute | Size | Input Type | Requirement |
| PostCode | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
Element Attribute Size Input Type Requirement
| City | 1 to 200 characters | stf:StringMin1Max200_Type | Validation | |
| Element | Attribute | Size | Input Type | Requirement |
| CountrySubentity | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
The above data elements comprise the AddressFix type.
III CbC Body
The CbC Body contains the information on the Constituent Entities, including the Reporting Entity, of the MNE Group for which a CbC Report is filed, as well as the key indicators of both the MNE Group as a whole and the individual Constituent Entities, as foreseen in the CbC reporting template.
| Element | Attribute | Size | Input Type | Requirement |
| CbcBody | cbc:CbcBody_Type | Validation |
The CbC Body element is composed of the following elements:
| Element | Attribute | Size | Input Type | Requirement |
| ReportingEntity | cbc:CorrectableReportingEntity_Type | Validation | ||
The Reporting Entity element contains the identifying information for the entity of the MNE Group that ensures the preparation and filing of the CbC Report.
| Element | Attribute | Size | Input Type | Requirement |
| CbcReports | cbc:CorrectableCbcReport_Type | Optional (Mandatory) |
The CbC Reports element contains, for each Tax Jurisdiction in which the MNE Group operates, the summary of key indicators, as well as a list of all Constituent Entities and their business activities.
| Element | Attribute | Size | Input Type | Requirement |
| AdditionalInfo | cbc:CorrectableAdditionalInfo_Type | Optional | ||
The Additional Info element allows entering any additional information on the CbC Report that the Reporting Entity wishes to make available to the receiving Competent Authorities in a free text format.
IIIa. ReportingEntity
| Element | Attribute | Size | Input Type | Requirement |
| ReportingEntity | cbc:CorrectableReportingEntity_Type | Validation | ||
As indicated above, this data element identifies the Reporting Entity and its role in the context of CbC reporting. It may be left blank in case a correction or deletion is carried out (see further guidance in the Corrections section below). The element is composed of:
| Element | Attribute | Size | Input Type | Requirement |
| Entity | cbc:OrganisationParty_Type | Validation |
This element contains the identifying information for the Reporting Entity. The Entity element uses the OrganisationParty_Type to provide the identifying information.
| Element | Attribute | Size | Input Type | Requirement |
| NameMNEGroup | 1 to 200 characters | stf:StringMin1Max200_Type | Optional |
This element allows specifying the name of the MNE Group by which the group is commonly known, in case this name differs from the name of the Reporting Entity.
| Element | Attribute | Size | Input Type | Requirement |
| ReportingRole | cbc:CbcReportingRole_EnumType | Validation | ||
The Reporting Role element specifies the role of the Reporting Entity with respect to the filing of the CbC Report. Possible values are:
- CBC701 – Ultimate Parent Entity
- CBC702 – Surrogate Parent Entity
- CBC703 – Local Filing in the framework of an international exchange (intra-EU exchanges only)
- CBC704 – Local Filing with Incomplete Information (intra-EU exchanges only)
The Reporting Period element indicates the Start and the End Date of the Fiscal Year of the MNE Group for which the CbC Report is filed.
| Element | Attribute | Size | Input Type | Requirement |
| StartDate | xsd:date | Validation |
This element contains the Start Date of the Fiscal Year of the MNE Group for which the CbC Report is filed.
| Element | Attribute | Size | Input Type | Requirement |
| EndDate | xsd:date | Validation |
This element contains the End Date of the Fiscal Year of the MNE Group for which the CbC Report is filed.
| Element | Attribute | Size | Input Type | Requirement |
| DocSpec | stf:DocSpec_Type | Validation |
DocSpec identifies the particular report within the CbC message being transmitted. It permits the identification of reports requiring correction (for further guidance see the Corrections section below).
IIIb. CbC Reports
As outlined above, the CbC Reports element contains, for each Tax Jurisdiction in which the MNE Group operates, the summary of key indicators, as well as a list of all Constituent Entities and their business activities. The CbC Reports element should be repeated for each Tax Jurisdiction in which the MNE Group operates through one or more Constituent Entities. It may be left blank in case a correction is carried out on the Reporting Entity element (see further guidance in the Corrections section below).
Any amounts should be provided in full units, i.e. without decimals, and any negative values should be identified by entering a “-” in front of the amount (e.g. USD -1000).
| Element | Attribute | Size | Input Type | Requirement |
| CbcReports | cbc:CorrectableCbcReport_Type | Optional (Mandatory) |
The CbC Reports element is composed of:
| Element | Attribute | Size | Input Type | Requirement |
| DocSpec | stf:DocSpec_Type | Validation |
DocSpec identifies the particular report within the CbC message being transmitted. It permits the identification of reports requiring correction (for further guidance see the Corrections section below).
| Element | Attribute | Size | Input Type | Requirement |
| ResCountryCode | 2-character | iso:CountryCode_Type | Validation |
This data element should contain the country code of the Tax Jurisdiction for which the summary of key indicators and the list of Constituent Entities and their business activities is prepared.
| Element | Attribute | Size | Input Type | Requirement |
| Summary | Validation |
The Summary element contains the key indicators of the MNE Group’s business activities in a relevant Tax Jurisdiction, as foreseen by the CbC reporting template.
| Element | Attribute | Size | Input Type | Requirement |
| ConstEntities | cbc:ConstituentEntity_Type | Validation |
The ConstEntities element contains the list of Constituent Entities (including the Reporting Entity) operating in a Tax Jurisdiction, as well as their business activities, as foreseen in the CbC reporting template.
IIIb. CbC Reports – Summary
| Element | Attribute | Size | Input Type | Requirement |
| Summary | Validation |
The Summary element, setting out the key indicators for the MNE Group’s business activities in a particular Tax Jurisdiction, is composed of:
| Element | Attribute | Size | Input Type | Requirement |
| Revenues | Validation |
Additional detail on the information to be provided in the Revenues element and its sub elements is available further below.
| Element | Attribute | Size | Input Type | Requirement |
| ProfitOrLoss | cbc:MonAmnt_Type | Validation |
In the Profit or Loss element, the sum of the profit or loss before income tax for all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction should be entered. The profit or loss before income tax should include all extraordinary income and expense items.
| Element | Attribute | Size | Input Type | Requirement |
| ProfitOrLoss | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| TaxPaid | cbc:MonAmnt_Type | Validation |
In the Tax Paid element, the total amount of income tax actually paid during the relevant fiscal year by all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction should be provided. Taxes paid should include cash taxes paid by a Constituent Entity to the residence Tax Jurisdiction and to all other Tax Jurisdictions. Taxes paid should
include withholding taxes paid by other entities (associated enterprises and independent enterprises) with respect to payments to the Constituent Entity. Thus, if company A resident in Tax Jurisdiction A earns interest in Tax Jurisdiction B, the tax withheld in Tax Jurisdiction B should be reported by company A.
| Element | Attribute | Size | Input Type | Requirement |
| TaxPaid | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| TaxAccrued | cbc:MonAmnt_Type | Validation |
In the Tax Accrued element, the sum of the accrued current tax expense recorded on taxable profits or losses of the year of reporting of all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction should be provided. The current tax expense should reflect only operations in the current year and should not include deferred taxes or provisions for uncertain tax liabilities.
| Element | Attribute | Size | Input Type | Requirement |
| TaxAccrued | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| Capital | cbc:MonAmnt_Type | Validation |
In the Capital element, the sum of the stated capital of all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction should be provided. With regard to permanent establishments, the stated capital should be reported by the legal entity of which it is a permanent establishment, unless there is a defined capital requirement in the permanent establishment Tax Jurisdiction for regulatory purposes. In such case, the capital attributed to a permanent establishment may be further specified in the Additional Info element.
| Element | Attribute | Size | Input Type | Requirement |
| Capital | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| Earnings | cbc:MonAmnt_Type | Validation |
In the Earnings element, the sum of the total accumulated earnings of all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction as of the end of the year should be provided. With regard to permanent establishments, accumulated earnings should be reported by the legal entity of which it is a permanent establishment.
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| NbEmployees | xsd:integer | Validation |
In the Nb Employees element, the total number of employees on a full-time equivalent (FTE) basis of all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction should be provided. The number of employees may be reported as of the year-end, on the basis of average employment levels for the year, or on any other basis consistently applied across Tax Jurisdictions and from year to year. For this purpose, independent contractors participating in the ordinary operating activities of the Constituent Entity may be reported as employees. Reasonable rounding or approximation of the number of employees is permissible, providing that such rounding or approximation does not materially distort the relative distribution of employees across the various Tax Jurisdictions. Consistent approaches should be applied from year to year and across entities.
| Element | Attribute | Size | Input Type | Requirement |
| Assets | cbc:MonAmnt_Type | Validation |
In the Assets elements, the sum of the net book values of tangible assets of all Constituent Entities resident for tax purposes in the relevant Tax Jurisdiction should be provided. With regard to permanent establishments, assets should be reported by reference to the Tax Jurisdiction in which the permanent establishment is situated. Tangible assets for this purpose do not include cash or cash equivalents, intangibles, or financial assets.
| Element | Attribute | Size | Input Type | Requirement |
| Assets | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
IIIb. CbC Reports – Summary – Revenues
| Element | Attribute | Size | Input Type | Requirement |
| Revenues | Validation |
In the Revenues element, the following information should be entered:
| Element | Attribute | Size | Input Type | Requirement |
| Unrelated | cbc:MonAmnt_Type | Validation |
In the Unrelated element the sum of revenues of all the Constituent Entities of the MNE Group in the relevant Tax Jurisdiction generated from transactions with independent parties should be indicated. Revenues should include revenues from sales of inventory and properties, services, royalties, interest, premiums and any other amounts. Revenues should exclude payments received from other Constituent Entities that are treated as dividends in the payor’s Tax Jurisdiction.
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| Related | cbc:MonAmnt_Type | Validation |
In the Related element the sum of revenues of all the Constituent Entities of the MNE Group in the relevant Tax Jurisdiction generated from transactions with associated enterprises is indicated. Revenues should include revenues from sales of inventory and properties, services, royalties, interest, premiums and any other amounts. Revenues should exclude payments received from other Constituent Entities that are treated as dividends in the payor’s Tax Jurisdiction.
| Element | Attribute | Size | Input Type | Requirement |
| Related | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
| Element | Attribute | Size | Input Type | Requirement |
| Total | cbc:MonAmnt_Type | Validation |
In the Total element the sum of the Unrelated and Related elements should be entered.
| Element | Attribute | Size | Input Type | Requirement |
| Total | currCode | 3 characters | iso:currCode_Type | Validation |
All amounts must be accompanied by the appropriate 3 character currency code based on the ISO 4217 Alpha 3 Standard.
IIIb. CbC Reports – Constituent Entities
| Element | Attribute | Size | Input Type | Requirement |
| ConstEntities | cbc:ConstituentEntity_Type | Validation |
The ConstEntities element is to be repeated for each Constituent Entity (including the Reporting Entity, if applicable) that is resident for tax purposes or subject to tax as a permanent establishment in the relevant Tax Jurisdiction and is composed of:
| Element | Attribute | Size | Input Type | Requirement |
| ConstEntity | cbc:OrganisationParty_Type | Validation |
In the ConstEntity element the identifying information for a Constituent Entity should be entered, using the OrganisationParty_Type.
| Element | Attribute | Size | Input Type | Requirement |
| Role | cbc:UltimateParentEntityRole_EnumType | Optional | ||
This element indicates the role of the Reporting Entity with respect to the MNE Group. It also allows the designation of the Ultimate Parent Entity of the MNE Group among the listed Constituent Entities. Possible values are:
- CBC801 – Ultimate Parent Entity
- CBC802 – Reporting Entity
- CBC803 – Both (Ultimate Parent Entity and Reporting Entity)
| Element | Attribute | Size | Input Type | Requirement |
| IncorpCountryCode | 2-character | iso:CountryCode_Type | Optional (Mandatory) |
In the IncorpCountryCode element, the Tax Jurisdiction under whose laws a Constituent Entity of the MNE Group is organised or incorporated should be indicated, if such Tax Jurisdiction is different from the Tax Jurisdiction of residence of the Constituent Entity.
| Element | Attribute | Size | Input Type | Requirement |
| BizActivities | cbc:CbcBizActivityType_EnumType | Validation | ||
In the BizActivities element, the nature of the main business activity(ies) carried out by a Constituent Entity in the relevant Tax Jurisdiction should be specified, by selecting at least one of the following codes:
- CBC501 – Research and Development
- CBC502 – Holding or Managing intellectual property
- CBC503 – Purchasing or Procurement
- CBC504 – Manufacturing or Production
- CBC505 – Sales, Marketing or Distribution
- CBC506 – Administrative, Management or Support Services
- CBC507 – Provision of Services to unrelated parties
- CBC508 – Internal Group Finance
- CBC509 – Regulated Financial Services
- CBC510 – Insurance
- CBC511 – Holding shares or other equity instruments
- CBC512 – Dormant
- CBC513 – Other
CBC 513 – Other should only be selected, in case the business activities of the Constituent Entity cannot be accurately reflected through the selection of one or more of the other codes. In case the CBC513 – Other code is selected, further information as to the business activities of the Constituent Entity is to be provided in the Other Entity Info element. Care should be given that, in instances where the BizActivities element is corrected, an according correction is also carried out in the Other Entity Info element, in case related information has been provided in that element.
| Element | Attribute | Size | Input Type | Requirement |
| OtherEntityInfo | 1 to 4’000 characters | stf:StringMin1Max4000_Type | Optional |
In the Other Entity Info element any further relevant information relating to a specific Constituent Entity may be entered in a free text format. In case additional information does not solely relate to a specific Constituent Entity, but also has relevance for the MNE Group as a whole, such information should instead be provided in the Additional Info element.
IIIc. Additional Info
| Element | Attribute | Size | Input Type | Requirement |
| AdditionalInfo | cbc:CorrectableAdditionalInfo_Type | Optional | ||
The Additional Info element allows any further brief information or explanation to be entered that is deemed necessary or that would facilitate the understanding of the compulsory information provided in the other elements of the CbC XML Schema in a free text format, provided such information does not solely relate to a specific Constituent Entity, in which case the information should be entered in the Other Entity Info element of the concerned Constituent Entity. However, information entered in the Additional Info element may be “tagged” as set out below, with a view to facilitating the association of the information provided to particular jurisdictions and/or specific elements of the Summary element of the CbC Report.
The Additional Info element is composed of:
| Element | Attribute | Size | Input Type | Requirement |
| DocSpec | stf:DocSpec_Type | Validation |
DocSpec identifies the particular report within the CbC message being transmitted. It permits the identification of reports requiring correction (for further guidance see the Corrections section below).
| Element | Attribute | Size | Input Type | Requirement |
| OtherInfo | 1 to 4’000 characters | stf:StringMin1Max4000_Type | Validation |
The Other Info element allows additional information to be entered in a free text format. Per entry, a maximum of 4’000 characters are allowed. In case more space is needed, the Additional Info element may be repeated, as required.
The OtherInfo is a repeatable element, but should only be repeated for transliteration purposes. In all other instances, a new Additional Info element should be generated.
| Element | Attribute | Size | Input Type | Requirement |
| OtherInfo | language | 2 characters | iso:LanguageCode_Type | (Optional) Mandatory |
The language attribute specifies the language in which the content of the OtherInfo element by indicating the relevant language code pursuant to ISO 639 – Part 1 (ISO 639- 1:2002). When the OtherInfo is repeated for transliteration purposes, the Language attribute must be provided.
| Element | Attribute | Size | Input Type | Requirement |
| ResCountryCode | 2-character | iso:CountryCode_Type | Optional |
For each Additional Info element, it is possible to indicate that the information provided specifically relates to one or more jurisdictions. In that case the relevant country codes should be entered in the ResCountryCode element.
The ResCountryCode list now contains a country code (XX) that allows MNE Groups to specify a country that is not currently contained in the ISO country list. The XX country code should only be used in these specific, exceptional circumstances where there is no adequate ISO country code available and should never be used in the context of the MessageSpec elements.
| Element | Attribute | Size | Input Type | Requirement |
| SummaryRef | cbc:CbcSummaryListElementsType_EnumType | Optional | ||
In addition, it is possible to indicate, for each Additional Info element, that the information provided specifically relates to one or more particular elements of the Summary element by selecting one or more of the corresponding values below. By doing so, the information contained in the relevant Additional Info element will be “tagged”, therewith facilitating the review of the CbC Report by the receiving jurisdiction(s).
The possible values, reflecting the structure of the Summary element, are:
- CBC601 – Revenues – Unrelated
- CBC602 – Revenues – Related
- CBC603 – Revenues – Total
- CBC604 – Profit or Loss
- CBC605 – Tax Paid
- CBC606 – Tax Accrued
- CBC607 – Capital
- CBC608 – Earnings
- CBC609 – Number of Employees
- CBC610 – Assets
- CBC611 – Name of MNE Group
IV Currency
All amounts provided in the Country-by-Country Report should be reported in one and the same currency, being the currency of the Reporting MNE. If statutory financial statements are used as the basis for reporting, all amounts should be translated to the stated functional currency of the Reporting MNE at the average exchange rate for the year stated in the Additional Info element.
V Schema version
The version of the schema and the corresponding business rules have a unique version number assigned that usually consists of two numbers separated by a period sign: major and minor version (ex: 2.0). The version number could also contain a third number
(ex: 2.0.1) which indicates that the schema was revised with very minor changes (ex: only new enumerations were added).
The version is identified by the version attribute on the schema element. The target namespace of the CbC schema contains only the major version.
<xsd:schema xmlns:cbc=”urn:oecd:ties:cbc:v2″ xmlns:xsd=”http://www.w3.org/2001/XMLSchema” xmlns:stf=”urn:oecd:ties:cbcstf:v5″ xmlns:iso=”urn:oecd:ties:isocbctypes:v1″ targetNamespace=”urn:oecd:ties:cbc:v2″ elementFormDefault=”qualified” attributeFormDefault=”unqualified” version=”2.0″>
<xsd:import namespace=”urn:oecd:ties:isocbctypes:v1″ schemaLocation=”isocbctypes_v1.1.xsd”/>
<xsd:import namespace=”urn:oecd:ties:cbcstf:v5″ schemaLocation=”oecdcbctypes_v5.0.xsd”/>
Element Attribute Size Input Type Requirement
CBC_OECD version 1 to 10 characters stf:StringMin1Max10_Type (Optional) Mandatory
Element Attribute Size Input Type Requirement
CBC_OECD version 1 to 10 characters stf:StringMin1Max10_Type (Optional) Mandatory
The root element CBC_OECD version attribute in the XML report file must be set to the value of the schema version. This will identify the schema version that was used to create the report.
For the CbC schema version 2.0, the version attribute must be set to the value “2.0”.
VI Transliteration
Where transliteration is required because sending and receiving jurisdictions do not use a common alphabet, Competent Authorities may agree how they will undertake such transliteration. If there is no such agreement, then a sending jurisdiction should, if so requested, transliterate from its own non-Latin domestic alphabet or literation to the Latin alphabet aligned with international standards for transliteration, as specified in ISO 8859. The sending jurisdiction may send designatory data (e.g. name or address) in both its non-Latin domestic alphabet or literation and separately in the Latin alphabet within each record if it so chooses. A receiving jurisdiction should also be prepared to transliterate from the Latin alphabet to its own non-Latin domestic alphabet or literation.
CbC Reporting 