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CbC Exchange MoU between Hong Kong and South Africa Signed

13 November 2017

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Treaty Development

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Hong Kong-South Africa

According to an update from the South African Revenue Service, a Memorandum of Understanding on the exchange of Country-by-Country (CbC) Reports has been signed with Hong Kong. The MoU provides that CbC reports voluntarily filed by Hong Kong MNE groups in Hong Kong for the 2016 and 2017 fiscal years will be exchanged with South Africa, and given that exchange, South Africa will not require local filing of CbC reports in South Africa by such MNE groups. Note - As per the Hong Kong Inland Revenue's CbC reporting guidance page (and OECD guidance), the voluntary filing of CbC reports in...