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U.S. IRS Does Not Anticipate Concluding CbC Exchange Agreements in 2018 with Countries Not Already Listed in CbC Reporting Jurisdiction Status Table

13 November 2018

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Treaty Development

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United States

In an update to the IRS Country-by-Country Reporting Jurisdiction Status Table published 9 November 2018, the IRS has noted that it does not anticipate concluding competent authority agreement negotiations in 2018 with any jurisdictions not appearing in the table as of that date. As such, U.S. MNE groups operating in jurisdictions that are not listed but have CbC reporting obligations for fiscal years beginning 1 January 2017 will need to review their obligations with respect to secondary local filing by constituent entities resident in these jurisdictions.