RoyaltyStat Blog

OECD Released the Country-by-Country XML Schema

Posted by Ednaldo Silva

The OECD released the Country-by-Country (CbC) reporting XML shema. This release contains the User Guide for the OECD’s standardized electronic format for the exchange of CbC Reports between jurisdictions – the CbC XML Schema. See

The CbC XML Schema is part of the OECD’s work to ensure the implementation of the BEPS measures, endorsed by G20 Leaders as part of the final BEPS Package in November 2015.

CbC Reports (to be electronically transmitted between Competent Authorities in accordance with the CbC XML Schema) is aimed to assist tax administrations in obtaining a better understanding of the way in which Multinational Enterprises (MNEs) structure their related-party operations, by annually providing key information on the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group. It will also cover information about which entities do business in a particular jurisdiction and the business activities each entity engages in.

The information to be included in the CbC Report will be collected by the country of residence of the Reporting Entity for the MNE group, and will then be exchanged in the format of the CbC XML Schema. First exchanges of CbC Reports will start in 2018, with information on the year 2016.

The CbC XML Schema User Guide further explains the information required to be included in each data element to be reported. It also contains guidance on how to make corrections of data element within a file. Read more about transfer pricing documentation and CbC reporting, the OECD BEPS Action 13:


Published on Mar 22, 2016 5:27:04 PM

Ednaldo Silva (Ph.D.) is founder and managing director of RoyaltyStat. He helped draft the US transfer pricing regulations and developed the comparable profits method called TNNM by the OECD. He can be contacted at:

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Topics: OECD BEPS Action