The Internal Revenue Service (IRS) published a joint statement with the competent authority of the United states of America and the competent authority of the French republic on the implementation of the spontaneous exchange of country-by-country reports for fiscal years beginning in 2020 and 2021.
The Competent Authorities are negotiating a competent authority agreement and arrangement to allow for the automatic exchange of CbC Reports. The Competent Authorities, without waiting for the negotiation’s conclusion, desire to exchange CbC Reports with respect to fiscal years of MNE Groups commencing on or after January 1, 2020 and before January 1, 2022. The Competent Authorities intend to exchange the CbC Reports spontaneously through a common schema in Extensible Markup Language (XML).
