The Jersey Government has published the Memorandum of Understanding on the exchange of Country-by-Country (CbC) Reports with Hong Kong, which entered into force on 31 December 2018. The MoU provides that CbC reports filed by Hong Kong MNE groups in Hong Kong for the 2017 and 2018 fiscal years will be exchanged with Jersey in accordance with the exchange provisions of the 2012 tax treaty between the two jurisdictions, and given that exchange, Jersey will not require local filing of CbC reports in Jersey by such MNE groups. Further, the MoU provides that Hong Kong will not require local filing in respect of groups headquartered in Jersey for the 2018 fiscal year, which is the first year Hong Kong's CbC reporting requirements formally apply (for 2017, reports may be filed voluntarily).
Note – Hong Kong has also activated exchange relationships under the CbC MCAA with Jersey and other jurisdictions, but this is not effective until the 2019 fiscal year.
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