On 2 December 2020, the U.S. IRS published a joint statement from the competent authorities of the U.S. and Germany on the implementation of the spontaneous exchange of country-by-country (CbC) reports for fiscal years beginning in 2019. Such joint statements were made for 2016, 2017, and 2018 as well.

The joint statement provides that CbC Reports for fiscal years of MNE Groups commencing on …