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OECD Updates Activations of Exchange Relationships for CbC Reports

The OECD has updated its webpage on activated exchange relationships for Country-by-Country (CbC) reports. The update includes activated exchange relationships for:

  • Bermuda, with 50 jurisdictions as sending and 2 as receiving (non-reciprocal);
  • Curaçao, with 46 jurisdictions as sending only (non-reciprocal);
  • Hong Kong, with 36 jurisdictions as sending and 40 as receiving; and
  • Liechtenstein, with 53 jurisdictions as sending, and 59 as receiving.

Based on the exchange relationships page, both Bermuda and Curaçao are non-reciprocal jurisdictions under the CbC MCAA, meaning they will send CbC reports but will not receive CbC reports under the agreement. For Bermuda, the exchange relationships page does, however, include reciprocal exchange with the UK and the U.S. under bilateral agreements. With respect to Bermuda-U.S., this appears to be in error as the CbC exchange arrangement between them only provides for the sending of CbC reports received by Bermuda to the U.S. (previous coverage). Reciprocal exchange with respect to Bermuda-UK is uncertain.

With respect to Hong Kong and Liechtenstein, the difference in exchange relationships for sending and receiving is due to certain exchange jurisdictions being non-reciprocal.

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