Johann Müller, International tax professional
Build contacts with people at DG TAXUD and DG Competition to facilitate a dialogue regarding international corporate taxation.
ID: 480037618392-94
Lobbying Activity
Response to Public country-by-country on corporate - template and electronic format
16 Aug 2024
Dear Madam, Sir, I have filed many CbCR reports for different MNEs in many different countries since 2016 both as being in-house and as a service provider. Please, please do not ask MNEs to file this report in XBRL. Base the report on the OECD CbCR xml schema as much as possible instead. Do not add or subtract anything from that report that is not strictly necessary. This will literally save MNEs weeks in compliance time and 10's of thousands of Euros in compliance costs annually. MNEs remember well when they did the OECD CbCR xml schema for the first time. They were swamped with Big4 online tools, ridiculously expensive third party tools, all just to convert their Excel files into xml, something most of us never heard of until then? MNEs remember the emails back and forth, the changes of letters in the reports to make them UTF-8 compliant, all just to get the xml file to validate. And they recall the frustration of trying to get those files uploaded to government website? Our files were being rejected multiple times and the one error message being more unclear than the next. Now imagine our governments telling us: We still want you to file that xml file every year. But we also want you to file most of that exact same data in a completely format, something you probably never worked with as a tax department before. You are not allowed to just take your OECD CbCR xml file, leave out a couple of rows about e.g. capital and assets, and add some rows about subsidiaries. No, no. We want you to convert the whole thing into something completely different (we are tax people not IT people). We want you to go find new expensive third parties, make new Excel templates for them to convert to XBRL, pay them lots of money, struggle with new validation, new uploads, additional reviews of the same data, etc.. This is exactly what the EU is doing right now. The same countries that asked MNEs at the OECD to file their CbCR data in xml, is now asking them at the EU to file that very same data in XBRL. I do not know the reasoning behind this, but I do know that this is unnecessarily multiplying the compliance cost, compliance burden and chances of deviation from the OECD CbCR filings, not once only, but year after year. It turns a 5-hour exercise which could have been done by a savvy in-house tax department, into a multiple week, costly, exercise for which most MNEs would need to hire yet another service provider. And it adds nothing to the data that will be made available to the public. The public does not read XBRL, and it is easy to make an xml parser to turn xml into a humanly readable format. I know, because I have done for CbCR xml files. See attached graphic. I am happy to expand on the above, if you wish me to. Yours sincerely, Johann Müller
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