According to an update to the IRS CbC Reporting Jurisdiction Status Table, the Country-by-Country (CbC) Report exchange agreement and related competent authority arrangement with German became operative on 4 April 2023. As established in the arrangement, pursuant to the provisions of Article 26 (Exchange of Information and Administrative Assistance) of the 1989 U.S.-Germany tax treaty, each competent authority intends to automatically exchange CbC reports received from each reporting entity resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC report, one or more constituent entities of the MNE group of the...