An updated the list of participating jurisdictions under the Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country (CbC) (Decision No. RO 2024 738) was published in the Swiss Official Gazette on 3 December 2024.

Under Decision No. RO 2024 738; Armenia, Georgia, and Montenegro have been added to the MCAA. The updates will take effect in stages, with Montenegro joining from 1 January 2024, Georgia from 1 January 2025, and Armenia from 1 January 2026.

The decision entered into force on 1 December 2024.

The MCAA is a multilateral framework agreement that provides a standardised and efficient mechanism to facilitate the automatic exchange of information. It avoids the need for several bilateral agreements to be concluded. Its design as a framework agreement means the MCAA always ensures each signatory has ultimate control over exactly which exchange relationships it enters into and that each signatoryā€™s standards on confidentiality, data protection and appropriate use of information always apply.

Country-by-Country Reporting (CbCR), with the specific document for an entity known as a Country-by-Country report or CbC report, is an international initiative led by the OECD. It sets a reporting standard for multinational enterprises (MNEs) with total consolidated group revenues exceeding EUR 750 million.

This standard requires the disclosure of key tax-related information, including financial data, employee details, and non-cash tangible assets. While OECD rules mandate that this information be exchanged between the tax authorities of participating countries, the EU has enacted legislation requiring that Country-by-Country reports be made publicly accessible after 2024.