The Revenue electronic system is not ready to accept the first Country By Country (CbC) Reports which are due to be filed by relevant taxpayers on or before 31 December 2017. Therefore the deadline for filing such reports is extended to 28 February 2018.

Revenue tells us that the electronic CbC Reporting filing system includes a standard validation module that is being provided by the EU Commission. However, due to late changes to the CbC Reporting schema, the final version of the validation module is not yet available. This means that Revenue cannot accept CbC reports.

According to eBrief No. 107/17, the tested version of the validation module is expected to be received in mid-December and integrated with the Revenue system shortly thereafter. As a consequence, CbC Reports for fiscal years ending in 2016 can be filed up to 28 February 2018.

CbC Reporting filing obligations are contained in section 891H of the Taxes Consolidation Act 1997 and the Taxes (Country-by-Country Reporting) Regulations 2016.

Revenue published updates to their Country by Country Reporting (CbCR) FAQs.

Revenue has confirmed to us that the recent updates to the FAQs are as follows:

• Q3 has been updated to provide a link to the OECD implementation guidance on CbCR.
• Q11 and 22 have been amended to reflect a number of developments:
1. The last paragraph of Q11 has been removed. This is to reflect the fact that the address of each constituent entity is not mandatory on the XML schema.
2. Q22 has been updated to:
1. Indicate that the ROS filing system is anticipated to go live by the end of November and taxpayers should proceed with the preparation of their XML files using the XML Schema in advance of that date. Links to both the XML Schema and the User Guide have been provided.
2. Remind taxpayers to ensure that they have made any necessary notifications well in advance of the filing date.
• New Q23, 24 and 25 have been included to cover a number of XML filing issues.
• Q27 has been updated to reflect that, Ireland will accept the OECD transitional relief for MNE groups with short accounting periods in 2016. The OECD guidance on this issue was published in September. See question 3: https://www.oecd.org/tax/guidance-on-the-implementation-of-country-by-country-reporting-beps-action-13.pdf. In addition the question now deals with long accounting periods.
• Q37 has been updated to reflect the most recent number of signatories to the MCAA and regarding activated bilateral exchange relationships.
• Q38 has been updated to confirm that equivalent CbC Reports, which contain information on constituent entities or PEs in Member States, will be exchanged with those Member States in accordance with the provisions of DAC 4.
• A new Appendix IV has been inserted dealing with naming conventions in relation to the XML filing of CbC Reports.

The FAQs are available on the Revenue website