The U.S. IRS has published a joint statement with the competent authority of Hungary on the implementation of the spontaneous exchange of country-by-country (CbC) reports for fiscal years beginning in 2021. The joint statement with Hungary provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2021 and before 1 January 2022 that are filed with the U.S. IRS will be spontaneously exchanged with the competent authority of Hungary pursuant to the 1988 Mutual Assistance Convention. Where a CbC report of a U.S. MNE group is exchanged with Hungary, then none of the constituent...