The U.S. IRS has published the competent authority arrangements on the exchange of Country-by-Country (CbC) reports with Estonia and the Isle of Man. The arrangement with Estonia was signed 26 July 2017 and the arrangement with the Isle of Man was signed 20 July 2017.
The arrangements provide that pursuant to the exchange of information provisions of the 1998 income tax treaty with Estonia and the 2002 tax information exchange agreement with the Isle of Man, as amended (2013), each competent authority will automatically exchange CbC reports received from each reporting entity resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC report, one or more constituent entities of the MNE group of the reporting entity are resident for tax purposes in the jurisdiction of the other competent authority, or are subject to tax with respect to the business carried out through a permanent establishment situated in the other jurisdiction.
With respect to Estonia, CbC reports will be exchanged for fiscal years beginning on or after 1 January 2016, with the first exchange to take place no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC report relates (15 months for subsequent years).
With respect to the Isle of Man, CbC reports will be exchanged for fiscal years beginning on or after 1 January 2017, with the first exchange to take place no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC report relates (15 months for subsequent years).
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