On 26 November 2019, the U.S. IRS published the 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 2018. Such joint statements were made for 2016 and 2017 as well. The joint statement provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2018 and before 1 January 2019 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, as amended. The joint...