On 10 August 2021, the German Ministry of Finance published a joint statement by the competent authorities of Germany and the U.S. on the implementation of the spontaneous exchange of country-by-country (CbC) reports for fiscal years beginning in 2020. Such joint statements were made for 2016, 2017, 2018, and 2019 as well. The joint statement provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2020 and before 1 January 2021 will be spontaneously exchanged pursuant to Article 26 (Exchange of Information and Administrative Assistance) of the 1989 Germany-U.S. income and capital tax treaty,...