On 10 May 2023, Germany has announced the official entry into force of its Country-by-Country (CbC) Report exchange agreement with the United States, as published in the Official Gazette. The agreement, which became effective on 4 April 2023, marks a significant step towards enhanced international cooperation in tax matters between the two countries.
However, it is important to note that the exchange of information under the agreement is still pending until the competent authority arrangement for exchange becomes operational. The specific dates for the operationalization of both the exchange agreement and the competent authority arrangement are yet to be determined, as indicated by the IRS CbC Reporting Jurisdiction Status Table.
This development highlights Germany’s commitment to transparency and collaboration in combating tax evasion and ensuring fair taxation practices in line with international standards.