On 5 December 2019, the U.S. IRS published the joint statement from the competent authorities of the U.S. and France 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 that are filed with the U.S. IRS will be spontaneously exchanged with competent authority of France pursuant to Article 27 (Exchange of Information) of the 1994 France-U.S....