Country-by-country reporting enables automatic CbC report exchange among competent authorities, subject to non-reciprocal listings where applicable. Automatic exchange of Country-by-Country (CbC) Reports requires each Competent Authority to annually transmit CbC Reports from Reporting Entities resident in its jurisdiction to other Competent Authorities of Jurisdictions party to the Agreement when the CbC Report shows Constituent Entities are resident for tax purposes or taxable through a permanent establishment; Jurisdictions designated as non-reciprocal will send but not receive CbC Reports, and Competent Authorities will not send reports to those non-reciprocal Jurisdictions.
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.
Country-by-country reporting enables automatic CbC report exchange among competent authorities, subject to non-reciprocal listings where applicable.
Automatic exchange of Country-by-Country (CbC) Reports requires each Competent Authority to annually transmit CbC Reports from Reporting Entities resident in its jurisdiction to other Competent Authorities of Jurisdictions party to the Agreement when the CbC Report shows Constituent Entities are resident for tax purposes or taxable through a permanent establishment; Jurisdictions designated as non-reciprocal will send but not receive CbC Reports, and Competent Authorities will not send reports to those non-reciprocal Jurisdictions.
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