On 14 December 2018, the U.S. IRS published the Joint Statement from the competent authorities of the U.S. and Germany on the implementation of the spontaneous exchange of country-by-country (CbC) reports for fiscal years beginning in 2017. The joint statement, which was signed on 13 December, provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2017 and before 1 January 2018 will be spontaneously exchanged pursuant to Article 26 (Exchange of Information and Administrative Assistance) of the 1989 Germany-U.S. income and capital tax treaty, as amended. The joint statement also notes that the...