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U.S. Publishes CbC Exchange Arrangement with Mexico

08 November 2017

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Treaty Development

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United States-Mexico

The U.S. IRS has published the competent authority arrangement on the exchange of Country-by-Country (CbC) reports with Mexico. The arrangement was signed 19 October 2017 and is operative (effective) from that date. The arrangement provides that pursuant to Article 4 (Exchange of Information) of the 1989 Mexico-U.S. tax information exchange agreement, as amended, 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 reporting entity...