According to an announcement on the IRS website, the competent authorities of the U.S. and United Kingdom have concluded an arrangement for the exchange of Country-by-Country Reports. The competent authority arrangement (CAA) for exchange of country-by-country reports is in line with the provisions of the double tax convention between the countries. The agreement was signed on 16 August 2017.
Under the arrangement, the first fiscal year for which the U.S. and UK intend to exchange CbC reports is the fiscal year 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.
The Competent Authorities intend to exchange the CbC Reports automatically through a common schema in Extensible Markup Language (XML).
