On 4 November 2020, IRS published the updated information on CbC reporting jurisdiction status table. Accordingly, on 14 August 2020, U.S. and Germany sign an agreement on exchange of Country-by-Country reports.
Each Competent Authority intends to exchange with the other Competent Authority annually on an automatic basis. The CbC Report received from each Reporting Entity that is 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 the MNE Group of the Reporting Entity are resident for tax purposes in the jurisdiction of the other Competent Authority, or are subject to tax with respect to the business carried out through a permanent establishment situated in the jurisdiction of the other Competent Authority.
