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New CbC Exchange MoU between Hong Kong and South Africa Signed for 2017 and 2018

04 January 2019

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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 new Memorandum of Understanding on the exchange of Country-by-Country (CbC) Reports was signed with Hong Kong on 30 November 2018. The MoU provides that CbC reports filed by Hong Kong MNE groups in Hong Kong for the 2017 and 2018 fiscal years will be exchanged with South Africa in accordance with the exchange provisions of the 2014 tax treaty between the two jurisdictions, and given that exchange, South Africa will not require local filing of CbC reports in South Africa by such MNE groups. Further, the MoU provides that...