Strategizing International Tax Best Practices – by Keith Brockman

Thirty-one countries have signed the OECD’s multilateral competent authority agreement (MCAA) for the automatic exchange of country-by-country (CbC) reports, excluding the U.S.

The signatory countries are:

  1. Australia
  2. Austria
  3. Belgium
  4. Chile
  5. Costa Rica
  6. Czech Republic
  7. Denmark
  8. Estonia
  9. Finland
  10. France
  11. Germany
  12. Greece
  13. Ireland
  14. Italy
  15. Japan
  16. Liechtenstein
  17. Luxembourg
  18. Malaysia
  19. Mexico
  20. Netherlands
  21. Nigeria
  22. Norway
  23. Poland
  24. Portugal
  25. Slovak Republic
  26. Slovenia
  27. South Africa
  28. Spain
  29. Sweden
  30. Switzerland
  31. UK

The position of the US, noticeably absent from the list,  is to enter into bilateral agreements with appropriate countries that have safeguards and governance in place, as well as countries that have an income tax treaty or tax information exchange agreement in effect.

OECD BEPS Action 13 provided models for the recommended CbC reporting options; a multilateral agreement, a double tax convention model and a model based on a tax information exchange agreement.

It will be critical to monitor the development of the CbC exchange process, in addition to timing mismatches and the necessity to identify a surrogate country, with additional complexities to consider.

 

 

 

 

 

 

 

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