11/10/2017 - Today, a further step was taken to implement Country-by-Country Reporting in accordance with the BEPS Action 13 minimum standard, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports ("the CbC MCAA"). Over 1000 automatic exchange relationships have now been established among jurisdictions committed to exchanging CbC Reports as of mid-2018, including those between EU Member States under EU Council Directive 2016/881/EU.
It is expected that more jurisdictions will nominate partners with which they will undertake the automatic exchange of CbC Reports under the CbC MCAA in the coming weeks. In addition, the United States has now signed 27 bilateral competent authority agreements for the exchange of CbC Reports under Double Tax Conventions or Tax Information Exchange Agreements, with more under negotiation. Regular updates will be published on the OECD website on exchange relationships to provide clarity for MNE Groups and tax administrations.
The full list of automatic exchange relationships that are now in place is available, together with an update on the implementation of the domestic legal framework for CbC Reporting in jurisdictions.
This additional wave of activations of CbC Reporting exchange relationships is another important step towards the timely implementation of Country-by-Country Reporting and reflects the commitment of jurisdictions around the world to the fight against base erosion and profit shifting.
Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 6 26 30 49 23) or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 6 21 63 27 67).