According to an IRS announcement on its website, the competent authorities of U.S. and Guernsey have concluded an arrangement on the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country reports is on the basis of a tax information exchange agreement (TIEA). The agreement was signed on 22 June 2017.
Under the arrangement, the first fiscal year for which the U.S. and Guernsey intend to exchange CbC reports is the fiscal years of MNE Groups commencing on or after January 1, 2016. The CbC Report is intended to be exchanged as soon as possible and no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC Report relates. CbC Reports with respect to fiscal years of MNE Groups commencing on or after January 1, 2017 are intended to be exchanged as soon as possible and no later than 15 months after the last day of the fiscal year of the MNE Group to which the CbC Report relates.
The Competent Authorities intend to exchange the CbC Reports automatically through a common schema in Extensible Markup Language (XML).
