According to an update from the OECD, Andorra and San Marino signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 18 October 2018 and 10 October 2018, respectively. Based on the OECD's website for CbC exchange relationships, the CbC MCAA has not yet been activated in respect of either country, although it is expected that this will be updated in the near future with respect to Andorra, given that its CbC requirements apply for fiscal years beginning on or after 1 January 2018. With respect to San Marino, CbC reporting requirements have not yet been implemented, although the country is committed to implementation as a BEPS Inclusive Framework member and exchange will be activated after implementation is completed.
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