Automatic exchange of CbC reports triggers annual sharing where residency or PE nexus to the other jurisdiction is present. Automatic exchange of Country-by-Country (CbC) reports occurs annually between Competent Authorities when the CbC Report shows Constituent Entities of the MNE group are tax resident in, or taxable via a permanent establishment in, the other jurisdiction. Competent Authorities must execute an arrangement under the mutual agreement procedure to set timing and manner of exchange, transmission and error collaboration, confidentiality and data safeguards, consultation mechanisms, and provisions for modification and term, consistent with the Agreement and the Convention.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Automatic exchange of CbC reports triggers annual sharing where residency or PE nexus to the other jurisdiction is present.
Automatic exchange of Country-by-Country (CbC) reports occurs annually between Competent Authorities when the CbC Report shows Constituent Entities of the MNE group are tax resident in, or taxable via a permanent establishment in, the other jurisdiction. Competent Authorities must execute an arrangement under the mutual agreement procedure to set timing and manner of exchange, transmission and error collaboration, confidentiality and data safeguards, consultation mechanisms, and provisions for modification and term, consistent with the Agreement and the Convention.
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