The U.S. IRS has published the competent authority arrangement on the exchange of Country-by-Country (CbC) Reports with Turkey. The agreement was signed on 24 November 2021 and is operative (effective) from that date.

The arrangement provides that pursuant to the provisions of Article 26 (Exchange of Information) of the 1996 U.S.-Turkey income tax treaty, each competent authority intends to 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.

CbC reports are intended to be exchanged with respect to fiscal years of MNE groups commencing on or after 1 January 2019, with such CbC report 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 a CbC report relates. CbC Reports with respect to fiscal years of MNE groups commencing on or after 1 January 2020 are intended to be exchanged as soon as possible and no later than 15 months after the last day of the fiscal year of the MNE group to which a CbC report relates. However, the competent authorities have until three months after the arrangement is operative to first exchange reports (i.e., until 24 February 2022).