The U.S. IRS has published a joint statement with Germany on the spontaneous exchange of Country-by-Country (CbC) reports. The joint statement provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2016 and before 1 January 2017 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. Negotiations are ongoing for a competent authority arrangement to allow for the automatic exchange of CbC reports.