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U.S. Negotiating CbC Exchange Arrangements with Bulgaria and Gibraltar

10 October 2018

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Treaty Development

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United States-Bulgaria-Gibraltar

According to an update to the IRS Country-by-Country Reporting Jurisdiction Status Table, the U.S. had begun negotiations for competent authority arrangements on the exchange of Country-by-Country (CbC) Reports with Bulgaria and Gibraltar. Once finalized and signed, the exchange arrangements will likely apply with respect to reporting fiscal years beginning on or after 1 January 2017 given that the both Bulgaria's and Gibraltar's CbC reporting requirements for foreign-parented groups apply from that year. The arrangements will generally need to be signed by 31 December 2018 for U.S. MNEs to avoid potential local filing requirements in the respective jurisdictions.