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 signatory’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.