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U.S. Signs Two Competent Authority Agreements for Exchange of CbC Reports

02 May 2017

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Treaty Development

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United States-Netherlands

According to recent reports, the U.S. IRS has entered into bilateral competent authority agreements (BCAA) for the exchange of Country-by-Country (CbC) reports with the Netherlands and one other yet to be named country. The agreements are needed for U.S. based MNEs to avoid local filing requirements in the relevant countries they operate in, including for fiscal years for which CbC reports are filed in the U.S. voluntarily. A separate CBC BCAA will be needed with each jurisdiction that has adopted CbC reporting requirements. Information on U.S. CbC BCAA's is to be made available on the IRS CbC Reporting Guidance webpage....