Base erosion and profit shifting

Country-by-Country exchange relationships

 

ACTIVATED EXCHANGE RELATIONSHIPS FOR COUNTRY-BY-COUNTRY REPORTING 

 

Last updated: 4 May 2017

 

This section shows all bilateral exchange relationships that are currently in place for the automatic exchange of CbC Reports between tax authorities. More than 700 automatic exchange relationships have now been established among jurisdictions committed to exchanging CbC Reports as of 2018, including those between EU Member States under EU Council Directive 2016/881/EU. In addition, more jurisdictions will nominate partners with which they will undertake the automatic exchange of CbC Reports under the CbC MCAA in the coming months. Some jurisdictions also continue to work towards agreeing bilateral competent authority agreements for the automatic exchange of CbC Reports with specific partners under Double Tax Conventions or Tax Information Exchange Agreements. We are working toward publishing regular updates on exchange relationships to provide clarity for MNE Groups and tax administrations.

 

As of May 2017, there are now already over 700 bilateral exchange relationships activated with respect to more than 30 jurisdictions committed to exchanging CbC Reports, with first exchanges scheduled to take place in 2018 [read the press release].

 

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.

 

 

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