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Base erosion and profit shifting

Exchange on Tax Rulings XML Schema: User Guide for Tax Administrations

 

Exchange on Tax Rulings XML Schema: User Guide for Tax Administrations

 


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This publication contains the OECD's standardised IT-format for the exchange on tax rulings (ETR) between jurisdictions – the ETR XML Schema – as well as the related User Guide.

The first and current 2017 version of the ETR XML Schema and User Guide is applicable for all exchanges until 31 March 2020, whereas the second, the new June 2019 version will be in use as from 1 April 2020.

The ETR XML Schema supports the mandatory spontaneous exchange on tax rulings under BEPS Action 5, covering:

  1. Rulings related to preferential regimes;
  2. Cross border unilateral advance pricing arrangements (APAs) or other unilateral transfer pricing rulings;
  3. Rulings giving a downward adjustment to profits;
  4. Permanent establishment (PE) rulings;
  5. Conduit rulings; and
  6. Any other type of ruling where the FHTP agrees in the future that the absence of exchange would give rise to BEPS concerns.

The ETR 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.

 

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