• 2 December 2020 – Country-by-Country (CbC) System Changes

  • External BRS on the OECD CbC Reporting V 2.7.5
  • SARS CbC Schema version 2.0
  • SARS Country-By-Country File Declaration Sample V2.1

• 10 November 2020 – Country-by-Country (CbC) System Changes

  The Organisation for Economic Cooperation and Development (OECD) User Guide for Tax Administrations introduced in June 2019 outlines areas of improvement, which SARS and all participating administrations require you to adhere to. These system upgrades will bring consistency in the Country-by-Country (CbC) reporting, and enhance compliance across the OECD countries.
  
  The current XML Schema Version 1.0.1 and User Guide version 1.0.1 dated September 2017 will be upgraded to align with the new XML Schema version 2.0 from 1 February 2021. To enable SARS to implement the required system changes and to provide for testing of the system, the CbC eFiling system will be switched-off from 4 December 2020 to 31 January 2021, however, eFiling will still allow filing of master files and local files during this period.
  
  These upgrades will affect your organisation as all Multi-National Entities (MNEs) scheduled to file in December 2020 or January 2021 will now be required to file by 28 February 2021. However, those required to file by 28 February 2021 will now file on 31 March 2021. Please make the necessary changes to your XML file to align it to schema version 2.0 when uploading the CbC files. Alternatively, if an MNE prefers to capture the manual CbC01 form, the eFiling form will be enhanced by SARS to align with schema version 2.0.  Both functions will be available from 1 February 2021.
  
  SARS regrets the inconvenience caused by this change, and will remind MNEs of the above changes to reporting entities through a system message on eFiling. A formal public notice regarding the extension for impacted Multinational Entities will be published in due course.

• 22 June 2020 – CbC reporting: Upload functionality

  We would like to inform you that the Country-by-Country (CbC) Reporting XML file upload functionality is open for submissions from Friday 19 June 2020. SARS extends its appreciation and thanks to those Multi-National Entities (MNEs) who participated and collaborated in the initial testing phase of the upload functionality.
  • External BRS v2.6
  • External User Guide
  • CBCR XML Schema – September 2017
  • Guidance on the Implementation of Country-by-Country Reporting – Updated December 2019
  • SARS_File Declaration_Mapping Document v1.1
  • SARS CBC File Declaration v1.1
  • Sample XML – CBC File Declaration v1.3

• 30 May 2020 – Country-by-Country trade testing confirmed for 1 June – 12 June 2020

  SARS would like to extend its appreciation to the Multi-National Entities (MNEs) who confirmed their interest in participating in the trade testing of the Country-by-Country Reporting (CbC) XML file upload functionality.
  
  We would also like to thank those MNEs that have participated in the question and answer session hosted by SARS.
  
  SARS confirms that the Trade Testing will take place as planned from 1 June to 12 June 2020.
  
  A limited number of MNEs will participate in the trade testing and those that will participate would have received confirmation of the trade testing times and details of the test environment.

• 6 May 2020 – Clarity on the OECD reference documents relating to Country-by-Country (CbC) reporting

  See our correspondence issued to MNE’s to address the issue and also see the updated BRS on the OECD CbC Reporting version 2.5 and and OECD referenced documentation:
  • XML Schema version 1.0.1
  • User Guide version 1.0.1 dated September 2017

• 29 April 2020 – Invitation to participate in Trade Testing for Country-by-Country reporting submission functionality

  SARS is in the process of affording Multinational Entities (MNEs) an alternative functionality to enable them to submit their Country-by-Country (CbC) reports. See our correspondence to MNEs here and click here for the BRS on the OECD CbC Reporting version 2.4.

• 25 June 2018 – New exchange of information system kicks off

SARS has implemented a system that provides for the transmission of CbC reports to other tax jurisdictions in terms of the Multilateral Competent Authority Agreement (MCAA) and the bilateral Competent Authority Agreement, as well as the exchange of transfer pricing documentation on request between the participating authorities.

What is it?

Corporates and connected persons such as groups of companies, trusts, partnerships or natural persons and Multi-National Entities (MNEs) present some complex compliance risks.

 

To close the gaps and address the mismatches between the tax systems of multiple countries the Base Erosion and Profit Shifting (BEPS) Action Plan was adopted by the OECD and G20 countries, including South Africa, in 2013.

 

The OECD / G20 BEPS project provided the ambit for the development of Country-by-Country (CbC) reporting. CbC reporting requires MNE Groups to report on their operations in every country that they operate in. These reports will enable revenue authorities to assess transfer pricing risks and other BEPS related risks with respect to the MNE Groups operating in their countries. 

On 23 December 2016 (see Notice R.1598) regulations specifying the changes to the CbC Reporting Standard for MNE Groups specifically required for South Africa’s circumstances, were published under the Tax Administration Act, 2011. The South African CbC Regulations were closely modelled on the legislation related to CbC reporting published in the BEPS Action 13 (2015) Final Report.  In addition, a public notice (see Public Notice 1117) under section 25 of the Tax Administration Act requires the filing of the CbC Reports, master files and/or local files. An extension of the initial deadline for filing these reports were given in Public Notice 1308 of 8 December 2017. SARS will be able to receive and exchange information provided in the CbC Reports, master files and/or local files with other jurisdictions.  

The Ultimate Parent Entity or other MNE Entity must submit the required information as stipulated in the Business Requirements Specification (BRS): Country-by-Country and Financial Data Reporting. Local filing of a CbC Report (CbC01) by others members of an MNE Group is required in the circumstances as described in Article 2(2) read with Article 2(3) of the CbC Regulations. A list of countries that have a current International Agreement in place with South Africa but do not have a Qualifying Competent Authority Agreement in place for purposes of Article 2(2) is available on the link provided. The OECD website can be accessed for regular updates as jurisdictions activate their bilateral exchange relationships for CbC reporting

Country-by-Country Notifications

The CbC01 form is now available for electronic submission on the SARS eFiling platform using the CbC link. Kindly note that for the purpose of submitting the CbC01 form, currently SARS does not support submissions for CbC using any mobile devices. As mentioned the reporting requirements are stipulated in the BRS which also contains the requirements pertaining to the CbC01 form, master file and local file.

 

The master file and local file will have limitations in term of the size to be transmitted.  Each file should not exceed 5MB and combined files will be limited to 100MB per submission.  All documents will be converted to PDF when they are transmitted. 

The CbC Report will be saved on the SARS system for SARS use and transmission to other tax jurisdictions in terms of the Multilateral Competent Authority Agreement (MCAA) and bilateral Competent Authority Agreement. See the list of signatories to the MCAA.

 

On request from other tax jurisdictions, components of the master file and local file will be exchanged with such tax jurisdictions under treaty. 

Should you need more help, please send an email to Bus_Sys_CDSupport@sars.gov.za.

 

 

Country-by-Country(CbC) Documents​
BRS on the OECD CbC Reporting version 2.4