The U.S. IRS has published a joint statement with the competent authority of France on the implementation of the spontaneous exchange of country-by-country (CbC) reports for fiscal years beginning in 2022 and 2023. The joint statement with France provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2022 and before 1 January 2024 that are filed with the U.S. IRS will be spontaneously exchanged with the competent authority of France pursuant to Article 27 (Exchange of Information) of the 1994 France-U.S. income and capital tax treaty, as amended. Where a CbC report of...