Country-by-Country Report — instructions for Lomake.fi

MNE groups and comparable companies must submit the CbC Report for any fiscal year when consolidated turnover for the foregoing fiscal year has stood at €750 million as a minimum, and when the MNE group has – in addition to its Ultimate Parent Entity – at least one constituent entity in a foreign tax jurisdiction.  In most cases, the MNE group’s parent company is the party that submits the CbC Report.

In addition, a company that is not a member of an MNE group but is fully liable to pay tax, i.e. a resident taxpayer, has the obligation to submit the CbC Report if it is treated as having a permanent establishment in a foreign country and turnover has reached €750 million for the foregoing fiscal year before the submittal of the report.

The CbC Report is a combination of the Reporting Entity’s information, summaries for every tax jurisdiction with a specification of all the constituent entities that are involved, and additional information as necessary. You must file the CbC Report in 12 months from the end date of the fiscal year. More information on CbC reporting.

When you submit the report, please check that you have logged in to the e-service on the com­pany’s behalf.  You can change the setting on the top of the page: “Change taxpayer”. You have access to the e-service on the company’s behalf if you have received an authorisation for it.

The top part of the web form has a field where you can give the report a name.

Asterisks (*) denote required fields.

You can find the reports you have submitted earlier in My e-Services, and you can browse them and make corrections to them.

If you encounter any problems, send e-mail to siirtohinnoittelu(a)vero.fi at the Tax Administration to request that we contact you later.

Table of contents

1 New report
   1.1 New report: Type of report, and report ID
   1.2 New report: the Reporting entity and the reportable information
   1.3 New report: Country-by-country Report
      1.3.1 Country-by-Country information
      1.3.2 Overview of allocation of income, taxes and business activities by tax jurisdiction
      1.3.3 The Constituent Entities in the different countries
   1.4 New report: additional information
   1.5 New report: sending the CbC Report
2 Deleting a CbC Report that you have submitted earlier
   2.1 Deletion report: Type of report, and report ID
   2.2 Deletion report: the Reporting entity and the reportable information
   2.3 Deletion report: sending the CbC Report
3 Making corrections to a report submitted earlier
   3.1 Correction report: Type of report, and report ID
   3.2 Correction report: the Reporting entity and the reportable information
   3.3 Correction report: Country-by-country Report
      3.3.1 Country-by-Country information
      3.3.2 Overview of allocation of income, taxes and business activities by tax jurisdiction
      3.3.3 Constituent entities in the different countries
   3.4 Correction report: additional information
   3.5 Correction report: sending the correction report

1 New report

1.1 New report: Type of report, and report ID

If this is the first CbC Report for the fiscal year, the type-of-report setting is invariably “New report”. The e-service creates a Report ID automatically.  You can make no changes to the Report ID.

To delete a previously submitted report, or to make corrections to a previously submitted report, see section 2 (Deleting a report) or section 3 (Making corrections to a report) of this guide.

1.2 New report: the Reporting entity and the reportable information

This section of the fillable web form (section no 2) is for the basic identifying information of the Reporting Entity, the company that submits the CbC Report. The section also contains information on the report itself.

The default Type of the report is "I am adding data on the Reporting Entity below", when you are submitting the CbC Report for the first time for the tax year concerned.

Reporting entity’s identifying information

The electronic form will show the Business ID of the company that you have referred to when you logged in. Give the company’s name, i.e. the registered company name of the Reporting Entity.  If necessary, enter a parallel, alternative name of the multinational enterprise group into the Other name field.

Please note: If the Finnish Business ID does not appear automatically, make sure to check that you selected “I am submitting information for a company”, not your personal information.  If you need to change this setting, go to “Change taxpayer” on the top of the page. You can change the setting if you have the authorization to submit the report on the company’s behalf.

Reporting Entity's address

As a minimum, you must indicate the country of location related to the entity’s postal address, and the town, city or municipality.

Reporting Entity’s contact person

These spaces are for giving the name of a person to contact, i.e. of someone who can be contacted if we need further information about the CbC Report.

Reporting Entity's reporting role

Select the appropriate role. Ultimate Parent Entity is the most frequently occurring submitter of the CbC Report. Select that as the reporting role.

  • The reporting entity is the entity related to the MNE group that primarily submits the CbC Report to the Tax Administration. The reporting entity is often the MNE group’s ultimate parent entity. It may also be a company generally liable to tax but not an MNE group member, which is treated as having a permanent establishment in a foreign country.
  • “Surrogate parent entity” means the member company of the MNE group that has been designated as the entity filing the CbC Report by an Ultimate Parent Entity that resides outside the EU. The e-filed reports addressed to the Finnish Tax Administration refer to the Surrogate Parent Entity, and to the designated group company, with the Finnish words “nimetty selvitysvelvollinen”.
  • The Secondary Reporting Entity (“Domestic Constituent”) is the party submitting the CbC Report if the group’s Ultimate Parent Entity does not have to prepare the Report, and the other requirements are fulfilled as defined by law.

The foreign MNE group’s Ultimate Parent Entity

If the Ultimate Parent Entity is not a resident taxpayer in Finland, type the parent entity’s name and TIN, the Tax Identification Number.

If the MNE group’s parent refuses to give the information as required in the CbC Report, tick the appropriate box.

  • If there is a secondary reporting entity submitting the CbC Report to Finland, it must inform the Finnish Tax Administration of a situation where the secondary entity has asked the parent for the information in order to discharge the secondary entity’s obligation under § 14d, subsection 5 of the act on assessment procedure (Verotusmenettelylaki 1558/1995) but the foreign parent has refused. The obligation of the Secondary Reporting Entity only extends to submitting the information it has received or obtained if the MNE group’s ultimate parent entity in a foreign country has refused to provide information.

Language used for Additional Information

This space is for indicating the language if you will type any additional information about the company’s circumstances under “Additional Information”, section 4. We recommend English.

Reporting currency

This space is for indicating the name of the currency that you are using in the CbC Report information, under 3.2.

  • You can prepare the CbC Report in the currency that the Ultimate Parent Entity has prepared its consolidated financial statements in. Uniform use of one single currency everywhere on the completed form is required.

Fiscal year (=Accounting period)

Enter the start and end dates of the CbC Report’s accounting year. The format for the dates is yyyy-mm-dd. The “More information…” space is for any other notes regarding the fiscal year; for example, if your MNE group has changed the length of its accounting period, or if it uses a non-calendar year.

1.3 New report: Country-by-country Report

You are required to report the summaries and all Constituent Entities by tax jurisdictions. First, select the tax jurisdictions under section 3.1 Country-by-Country information, and then go to the 3.2 and 3.3 sections of the form to fill in the amounts and the values.

1.3.1 Country-by-Country information

This section (no 3.1) of the form is for giving details on the tax jurisdictions where your MNE group’s constituent entities are. If there is an entity that has no identifiable tax jurisdiction – which is exceptional – the value to select from the drop-down list is “X5 – ‘No Country’ – Ei valtiota".

Specify the Type of the report as "I am adding the data on the tax jurisdiction below" for submitting the CbC Report for the first time for the tax year concerned.

Click on Add the row to have the entries shown in the table below the entries and the spaces.

Repeat the above sequence until you have given all the information related to the tax jurisdictions that are reportable.

To make any checks and to review your entries regarding a specific tax jurisdiction, double-click on the relevant row. The previous entries are now displayed in the spaces on top. If more than 10 tax jurisdictions are listed on the table, you need to first click on the table and then press the arrow keys to scroll up and down.

To edit the data for a specific tax jurisdiction, double-click on the tax jurisdiction’s line first. After that, you can edit the jurisdiction’s information in the fields that are above. Click on Replace selected row to finish.

For removing any of the information saved in the table, double-click on the tax jurisdiction’s line to begin. After this, click on Delete selected row.

1.3.2 Overview of allocation of income, taxes and business activities by tax jurisdiction

This section of the fillable web form (section 3.2) is for filling in the summary information, tax jurisdiction by tax jurisdiction, listing the constituent entities that belong to the MNE group, or belong to your company.

Click on Add the row to have your new entries shown in the table below the spaces.

Please note! If you are unable to add a tax jurisdiction in section 3.2 of the fillable web form (Overview of allocation of income, taxes and business activities by tax jurisdiction), please re-check that you added the tax jurisdiction as it should be when you completed section 3.1 Country-by-Country information.

Repeat the above sequence as many times as is necessary to fill in the information on all tax jurisdictions.

To make any checks and to review the information you have entered, double-click on the relevant row of the table. Your entries are now displayed in the spaces on top. If more than 10 tax jurisdictions are listed on the table, you need to first click on the table and then press the arrow keys to scroll up and down.

To edit the data, double-click on the tax jurisdiction’s line first. After that, you can edit the information in the spaces that are above, and then click on Replace selected row to finish.

To remove a tax jurisdiction completely, double-click on the tax jurisdiction’s line first. Then click on “Delete selected row”.

1.3.3 The Constituent Entities in the different countries

This section (no 3.3) of the form is for giving details on the constituent entities one by one. “Constituent entity” refers to a wide range of legal forms of incorporation in various countries. Limited-liability companies, partnership entities with private individuals among the partners, and permanent establishments can be included. Any company can be held as a constituent entity within a MNE group if the decisions and control of that entity are under authority of the MNE group.

Indicate the country of tax residence, where the constituent entity has been set up i.e. established, and if its tax jurisdiction is not the same, additionally indicate the jurisdiction of tax residence.

Then, type the constituent entity’s Business ID. You are required to indicate the Finnish Business ID if the entity is in Finland. Otherwise, type the constituent entity’s TIN, comparable to the Finnish Business ID, which is issued by a foreign tax administration. If the entity has no TIN, you are required to indicate another foreign ID code and specify the Type of the foreign ID. In addition, give the name of the country that issued the other foreign ID.

Give the registered company name or business name of the constituent entity. If the entity is a permanent establishment, or if it is a branch office, the format for its name is: “Corporation X-Tax Jurisdiction Y PE”.

In the case of an Ultimate Parent Entity and in the case of a Reporting Entity, you also have to specify the Reporting role. The role selections within your MNE group are “Ultimate Parent Entity”, “Reporting Entity” and “Both”.

A frequently occurring situation for a Finnish parent company is that its role is “Reporting Entity” and it must submit the CbC Report. Accordingly, the role selection is “Both”. Less frequently, there are MNE groups where the parent company is outside Finland, but the Finnish member company of the group will submit the CbC Report. In this case, select “Ultimate Parent Entity” for the foreign parent’s role, and select “Reporting Entity” for the Finnish company that submits the report.

Constituent Entity’s address

These spaces are for the address information.

Constituent Entity’s main business activity

Make the selection(s) as appropriate. You are expected to select all the activities that are relevant in the selected tax jurisdiction as part of the entity’s major line of business.

Fill in Additional Information as necessary. Typically, this space is for giving some more information about the constituent entity’s business if the selection you made was “Other”.

Click on Add the Row to have the information displayed in the table below the fields.

Repeat the above sequence as many times as is necessary to provide information on all the constituent entities.

To make any checks and to review the information you have entered, double-click on the relevant row of the table. Your entries are now displayed in the spaces on top. If more than 10 constituent entities are listed on the table, you need to first click on the table and then press the arrow keys to scroll up and down.

To edit the date of the table, double-click on the constituent entity’s line. After that, you can edit the information in the fields that are above, and then click on Replace selected row to finish.

To remove the data on a constituent entity, first double-click on the line for the constituent entity concerned. After this, click on Delete selected row.

1.4 New report: additional information

This section (no 4) is for information such as the averaged currency-exchange rate that you have used when converting the different foreign currencies into your unified reporting currency. One of the recommended items of Additional Information is a description of the sources that you have used for your reported information. In addition, you are free to provide other facts, further information and accounts that can make the reported information easier to understand. In addition, you must indicate the reasons for it – why has there been a change of an information source, which you had relied on for previous years’ reports. You must also describe the effects that the changed source of information can have on the CbC Report.

If this is the first time you are submitting the CbC Report, set your Type of the report as “I am adding data to the tax jurisdiction below”.

If you are typing additional information for a specific tax jurisdiction, please select that tax jurisdiction from the drop-down list. You can also indicate the general subject matter that the additional information concerns.

After doing so, click on Add the Row to have the information displayed in the table below the spaces.

Repeat the above sequence until you have given all the information.

To make any checks and to review the information you have entered, double-click on the relevant row of the table. Your entries are now displayed in the spaces on top. If the table has more than 5 lines containing additional information, you need to first click on the table and then press the arrow keys to scroll up and down.

To make corrections to previously submitted data, double-click on the appropriate line. After that, you can edit the information in the fields that are above, and then click on Replace selected row to finish.

To delete something, you need to double-click on a line first. After this, click on Delete selected row.

1.5 New report: sending the CbC Report

After your CbC Report is completed, click on the Send button to send it. No acknowledgement-of-receipt message will arrive to you. However, you can check your CbC report’s current status in My e-Services. If you sent the report successfully, the word "Submitted” will appear next to its name.

To save an unfinished fillable web form in order to continue working on it some time later, click on “Save” in My e-Services. No information is yet being sent to the Tax Administration at this stage. You can come back later to fill in more spaces.

To reset the entire web form and to not send it, click on Cancel.

You can click on the Print (Tulosta) button to get a paper copy of the completed form before you submit or save it. Note: to click on the Print (Tulosta) button does not mean that you save any information or send any information to the Tax Administration.  In other words, to get a paper printout does not mean that you have received the Finnish Tax Administration’s acknowledgement of receipt.

2 Deleting a CbC Report that you have submitted earlier

If the Business ID of the reporting entity was wrong when the CbC Report was submitted, you need to delete it entirely. This is due to the fact that a Business ID entry cannot be changed. You must create a deletion report:

  1. Log in to My e-Services.
  2. First, look up the CbC Report that you need to delete.
  3. Click Use as Base to open it. Then you can continue to enter information as instructed under “2.1” below.

2.1 Deletion report: Type of report, and report ID

After you have clicked on Use as base to open the report, its Type is automatically displayed as “Correction or deletion report” (which you see under “1.”).

In the same way, the e-service also displays the original ID and assigns a new one for the deletion report you are about to submit. The original report’s ID is under “The RefID of the original report now being corrected”. You can make no changes to the identifiers yourself.

2.2 Deletion report: the Reporting entity and the reportable information

Specify the Type of the report in section 2 of the web form as “I am deleting all the previously submitted data regarding the Reporting Entity below”.

2.3 Deletion report: sending the CbC Report

Go to the bottom of the form and click on Send. Note: this command removes the entire previous report if your Type of the report is Deletion.

3 Making corrections to a report submitted earlier

Send a “Correction report” to make corrections to a report you have sent earlier. Please note that no combination of new input and corrections to previously submitted data (or removal of previously submitted data) is allowed on correction reports. In other words, one correction report is only for 2 alternative purposes: either you send new data, or you make corrections to old data and delete old data.

  1. Log in to My e-Services.
  2. First, look up the CbC report, other report, notice, etc. that you need to make corrections to.
  3. Click Use as Base to open it.
  4. Make the necessary corrections. The Correction report shows the previous entries as its template. For detailed instructions, see below under 3.1 – 3.5.

3.1 Correction report: Type of report, and report ID

After you have clicked on Use as base to open the report, its Type is automatically displayed as “Correction or deletion report” (which you see under “1.”).

In the same way, the e-service also displays the original ID and assigns a new one for the correction report you are about to submit. You can make no changes to the identifiers yourself.

3.2 Correction report: the Reporting entity and the reportable information

If your corrections only concern the CbC data, not the reporting entity’s information, you make your entries elsewhere. Accordingly, for section 2 of the form, just select “No changes were made to the previously submitted data on the Reporting Entity”.

However, if any changes regarding the reporting entity are made, select “I am making corrections to the data on the Reporting Entity below”. Then make the necessary corrections or changes.

3.3 Correction report: Country-by-country Report

Please note that the selections you make here in section 3.1 have an impact on what kind of changes you can make in the 3.2 and 3.3. sections.

Note: One correction report can only contain either new data or corrections and deletions of previously submitted data. No combinations of new input and corrections to previously submitted data are allowed.

3.3.1 Country-by-Country information

You can select the tax jurisdiction in 3.1 relating to the corrections you will make in the 3.2 and 3.3 sections.

For corrections to previously submitted data, first double-click on the line for the tax jurisdiction, and then specify your Type of the report as “I am making corrections to the summary information on the tax jurisdiction/Constituent Entities below”. Click on Replace selected row to finish. If more than 10 tax jurisdictions are listed on the table, you need to first click on the table and then press the arrow keys to scroll up and down.

If necessary, you can double-click on a tax jurisdiction first, and then specify “I am deleting all the previously submitted data regarding the tax jurisdiction below” in order to remove a tax jurisdiction with all its previous data. Click on Replace selected row to finish. The above sequence would also affect the 3.2 and 3.3 sections of the form, deleting all the data relative to the tax jurisdiction.

If your correction report concerns a new tax jurisdiction, you must first select it on the table to activate it, and then set “I am adding the data on the tax jurisdiction below” as Type of the report. Then, click on Add the row. Note: if you add a new tax jurisdiction with new data – or several new tax jurisdictions – no further corrections or deletions can be entered on this correction report.

3.3.2 Overview of allocation of income, taxes and business activities by tax jurisdiction

For corrections to previously submitted data, double-click on the line for the tax jurisdiction. Now you can proceed to enter the data in the relevant fields on the form. Click on Replace selected row to finish. If more than 10 tax jurisdictions are listed on the table, you need to first click on the table and then press the arrow keys to scroll up and down.  Please note that you can make corrections only if you specified the Type of the report above in 3.1 as “I am making corrections to the summary information on the tax jurisdiction/Constituent Entities below”.

If you are entering new information for a new jurisdiction, first select the tax jurisdiction, and then fill in the amounts and values for the country, and click on “Add the row” to finish. Please note that you can add a new jurisdiction only if you specified the Type of the report above in 3.1 as “I am adding the data on the tax jurisdiction below”.

3.3.3 Constituent entities in the different countries

For corrections to previously submitted data, double-click on the line for the constituent entity to activate it.  After making sure that you selected the right entity, make the corrections filling out the spaces that appear above the table. Click on Replace selected row to finish. If more than 10 entities are listed on the table, you need to first click on the table and then press the arrow keys to scroll up and down.

For removing a constituent entity’s information saved in the table, double-click on the constituent entity’s line to begin. Now you can click on Delete selected row to delete it.

If you are adding information regarding a new constituent entity, fill the spaces located above the table and then click on Add the row.

Please note that you can make corrections, delete an entity, or add one only if you specified the Type of the report above in 3.1 accordingly.

3.4 Correction report: additional information

For corrections to previously submitted additional information, first double-click on the appropriate line to activate it.  Then set “I am correcting previously submitted data on the tax jurisdiction below” as the Type of the report. If the table has more than 5 lines, you need to first click on the table and then press the arrow keys to scroll up and down. Now you can make the necessary corrections to the additional information, and then click on Replace selected row.

If you are removing some information that you had added earlier, double-click on the appropriate line to activate it first. Then set “I am deleting previously submitted data on the tax jurisdiction below” as Type of the report. Click on Replace selected row to finish.

If you are filling in some new information that you have not given previously, set the Type of the report as “I am adding data to the tax jurisdiction below”. Add the new information and click on Add the row.

3.5 Correction report: sending the correction report

After you have completed the correction report, click on Send to send it.