Base erosion and profit shifting

Country-by-Country exchange relationships

 

ACTIVATED EXCHANGE RELATIONSHIPS FOR COUNTRY-BY-COUNTRY REPORTING

Last updated: September 2018

 

This section shows all bilateral exchange relationships that are currently in place for the automatic exchange of CbC reports between tax authorities. 

 

As of September 2018, there are over 1800 bilateral exchange relationships activated with respect to jurisdictions committed to exchanging CbC reports, and the first automatic exchanges of CbC reports took place in June 2018. These include exchanges between the 72 signatories to the CbC Multilateral Competent Authority Agreement, between EU Member States under EU Council Directive 2016/881/EU and between signatories to bilateral competent authority agreements for exchanges under Double Tax Conventions or Tax Information Exchange Agreements, including over 35 bilateral agreements with the United States. Jurisdictions continue to negotiate arrangements for the exchange of CbC reports and the OECD will publish regular updates, to provide clarity for MNE Groups and tax administrations.

 

Activated exchange relationships can be sorted and displayed from both the perspective of a particular sending jurisdiction ("FROM") or a particular receiving jurisdiction ("TO"). For each exchange relationship, the legal basis and, where appropriate, the effective date and/or the activation date are shown. 

 

The number in brackets behind each jurisdiction in the drop-down menu indicates the total number of bilateral exchange relationships that are currently activated with respect to that jurisdiction. Where, for a particular jurisdiction, the number of exchange partners listed as sending CbC reports TO the jurisdiction is greater than the number of exchange partners listed as receiving CbC reports FROM the jurisdiction, this may be due to a number of these exchange partners being "non-reciprocal jurisdictions" (i.e. they have committed to send CbC reports to their exchange partners, but will not receive CbC reports from their exchange partners).

 

This page will be regularly updated as further jurisdictions activate their bilateral exchange relationships.

 

Further information

 

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