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U.S. Signs CbC Exchange Agreement with Germany

04 November 2020

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Treaty Development

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United States-Germany

According to a 3 November 2020 update to the IRS Country-by-Country Reporting Jurisdiction Status Table, the U.S. signed an agreement on the exchange of Country-by-Country (CbC) reports with Germany on 14 August 2020. The agreement provides that CbC reports will be automatically exchanged but with the terms of exchange to be set out in a separate competent authority arrangement. Exchange under the agreement will commence after the separate competent authority arrangement is operative. Note, for reporting fiscal years commencing before 1 January 2019, the U.S. has agreed to the spontaneous exchange of CbC reports with Germany. It is expected that...