Serbia joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (CbC MCAA) on 4 March 2025.
The Country-by-Country Multilateral Competent Authority Agreement (CbC MCAA) is grounded in Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters, as revised by the 2010 protocol.
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters (“the Convention”) was developed jointly by the OECD and the Council of Europe in 1988 and amended by the Protocol in 2010. It currently is the most comprehensive multilateral instrument available for all forms of tax cooperation to tackle tax evasion and avoidance.
This agreement facilitates the automatic exchange of country-by-country reports between nations, aligning with the objectives of BEPS Action 13. Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which they operate. This CbC report is shared with tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments.
As of 17 March 2025, a total of 110 jurisdictions have signed the CbC MCAA.
