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Hong Kong-France-Ireland-South Africa-United Kingdom

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Hong Kong Enters into Bilateral CbC Exchange Arrangement with France; Confirms Arrangements with Ireland, South Africa, and the UK

On 15 January 2018, the Hong Kong Inland Revenue Department announced that Hong Kong has entered into a bilateral arrangement with France for the automatic exchange of Country-by-Country (CbC) reports. Although Hong Kong's CbC reporting requirements have not yet been formally implemented and are not planned to apply until 2018 (previous coverage), Hong Kong is allowing voluntary parent surrogate filing in Hong Kong with respect to the 2016 and 2017 reporting fiscal years, which requires exchange arrangements to be effective in order to relieve local filing obligations in jurisdictions outside Hong Kong.

In addition to the arrangement with France, a 15 January update to Hong Kong's CbC reporting guidance page confirms that Hong Kong also has CbC exchange arrangements with Ireland, South Africa, and the UK. The arrangements all apply with respect to CbC reports from the 2016 reporting fiscal year.

Note - Hong Kong intends to give effect to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters for the purpose of exchanging CbC reports, but until the Convention is effective, CbC reports will be exchanged under the exchange provisions of applicable tax treaties if an arrangement is made.

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