On 21 December 2017, the OECD announced additional activations of exchange relationships for Country-by-Country (CbC) reports, as well as updated guidance on exchange relationships and implementation. Some of the key points of the updated guidance are as follows:
Conditions for Local Filing
With respect to the general conditions for secondary local filing, the guidance notes that the second condition, no agreement for CbC exchange, does not include circumstances where there is no inter…