The U.S. IRS has published the non-reciprocal bilateral competent authority arrangement on the exchange of Country-by-Country (CbC) reports with the Cayman Islands. The arrangement was signed 8 March 2017 and is operative (effective) from that date.
The arrangement provides that pursuant to the provisions of Article 6 (Automatic Exchange of Information) of the 2013 Cayman Islands-United States tax information exchange agreement, the Cayman Islands Competent Authority intends to exchange with the United States competent authority annually on an automatic basis the CbC Report received from each reporting entity that is resident for tax purposes in the Cayman Islands, 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 United States, or are subject to tax with respect to the business carried out through a permanent establishment situated in the United States.
With respect to fiscal years beginning on or after 1 January 2016, CbC reports are to be exchanged as soon as possible and no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC report relates. With respect to fiscal years beginning on or after 1 January 2017, reports are to be exchanged no later than 15 months after the last day of the fiscal year.
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