Tax & Accounting Blog

U.S. IRS Publishes List of Negotiating Countries for the Exchange of Country-by-Country Reports

BEPS, Blog, Global Tax Planning, International Reporting & Compliance September 5, 2017

The U.S. Internal Revenue Service (IRS) has updated its country-by-country (CbC) reporting jurisdiction status table, as of August 29, 2017, to include jurisdictions that are negotiating bilateral competent authority arrangements (CAAs) with the U.S. to exchange CbC information. The table also includes jurisdictions that have signed a CAA with the U.S. to exchange CbC reports. See BEPS Action 13.

The following jurisdictions are currently listed in the status table as “In Negotiations” with the U.S.: Colombia; Czech Republic; Finland; France; Germany; Hungary; India; Israel; Italy; Jersey; Liechtenstein; Lithuania; Luxembourg; Mauritius; Mexico; Poland; Portugal; Slovenia; Spain; and Sweden.

The following jurisdictions have signed a CAA with the U.S.: Australia; Belgium; Brazil; Canada; Denmark; Estonia; Guernsey; Iceland; Ireland; Isle of Man; Jamaica; Korea; Latvia; Malta; Netherlands; New Zealand; Norway; Slovakia; South Africa; and the U.K.

Background

On June 29, 2016, the IRS and Treasury released the Final CbC Regulations, which apply to tax years of ultimate parent entities of U.S. MNE groups that begin on or after June 30, 2016, when the MNEs have revenue for the preceding annual accounting period of at least $850 million.

On August 11, 2017, the IRS issued Bulletin 2017-2 on its acceptance of CbC report filings on IRS Form 8975. Ultimate parent entities of U.S. MNE groups with $850 million or more of revenues in a previous annual reporting period can now file Form 8975 and attached Schedule A with their annual U.S. corporate income tax return.