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Country-by-Country Reporting schema update in KSA

In May 2020, the General Authority of Zakat and Tax (GAZT) in the Kingdom of Saudi Arabia (KSA) has released the second edition of the Transfer Pricing guidelines which include a comprehensive step-by-step practical guidance around registration, notification and submission of Country-by-Country Reporting (CbCR ) on the Automatic Exchange of Information (AEOI) portal. KSA adopted the XML schema version 1.0., as prescribed by the Organization for Economic Co-operation and Development (OECD) for the CbCR submissions of FY18 and FY19 through the AEOI portal.

The OECD subsequently released guidance in 2019, announcing that XML version 2.0 schema will come into effect on 1 January 2021. As a result of the global COVID-19 crisis, the implementation date for international exchanges using the XML version 2.0 schema has been delayed by one month to 1 February 2021.

GAZT circulated an email on 19 January 2021, to taxpayers registered on the AEOI portal to announce that the portal is currently being updated to support XML version 2.0 schema.


Impact on businesses in the Kingdom of Saudi Arabia
 
  • The AEOI portal is currently offline in order to adapt to the new changes. It will be inaccessible from 18 January 2021 until further notice.
  • This change may impact Multinational Enterprise (MNE) Groups that have not yet filed their FY19 CbCR via the KSA ultimate parent entities or constituent entities with local filing obligations in the Kingdom. These MNE Groups would need to wait until the portal becomes accessible. 

Action points
 
  • For FY19 CbCR submissions that have already been filed – At this stage, we expect that no further action is required as the submissions were in line with the applicable XML schema version adopted by the Kingdom. However, we expect GAZT to provide further guidance on this when the AEOI portal becomes accessible again.
  • For FY19 CbCR submissions not yet filed with GAZT - There may be a delay in accessing the AEOI portal. The CbCR XML schema may need to be updated to the new 2.0 version.
  • For FY20 CbCR submissions - Moving forward, it is noted that for FY20 reports the new format will be adopted.
  • For CbCR notifications - It is expected that there will be no change to the CbCR notification procedure.

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