Base erosion and profit shifting

Country-by-Country exchange relationships




Last updated: April 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 April 2018, there are over 1500 bilateral exchange relationships activated with respect to jurisdictions committed to exchanging CbC Reports, with first exchanges scheduled to take place in June of this year. These include exchanges between the 68 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 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.


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



Related Documents