The U.S. IRS recently updated its Country-by-Country Reporting Jurisdiction Status Table including the note that it did not anticipate concluding CbC competent authority arrangement negotiations by 31 December 2019 with any jurisdiction not listed in the table. To date, several listed jurisdictions are also still marked as in negotiations. As such, U.S. MNEs need to review their potential local CbC report filing obligations for jurisdictions not listed and for those still listed as in negotiations. Certain jurisdictions, however, such as France and Germany, have made interim arrangements with the U.S. for exchange.
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