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U.S. Negotiating CbC Exchange Arrangement with Cyprus

19 June 2019

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Treaty Development

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United States-Cyprus

According to an update to the IRS Country-by-Country Reporting Jurisdiction Status Table, the U.S. had begun negotiations for a competent authority arrangement on the exchange of Country-by-Country (CbC) Reports with Cyprus. Once finalized and signed, the exchange arrangement will likely apply with respect to reporting fiscal years beginning on or after 1 January 2017 given that the Cyprus CbC reporting requirements apply from that year for non-resident parents. Note - Cyprus previously issued a notice including that local filing obligations for constituent entities of U.S. MNE groups could arise given that a CbC exchange arrangement had not been signed ({News-2018-09-26/A/2-previous...