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U.S. Signs CbC Exchange Arrangement with Japan

24 October 2018

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Treaty Development

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United States-Japan

According to an update to the IRS Country-by-Country Reporting Jurisdiction Status Table, the U.S. signed a competent authority arrangement on the exchange of Country-by-Country (CbC) reports with Japan on 12 October 2018. The arrangement is operative (effective) from the date it was signed. The arrangement provides that pursuant to Article 26 (Exchange of Information) of the 2003 Japan-U.S. tax treaty, 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...