Exchange of country-by-country reports requires automatic transmission between competent authorities under agreed electronic and encryption standards. The instrument requires specification of the currency in CbC Reports and establishes timing conditions for exchange: the first exchange for an MNE Group fiscal year commencing on or after a Competent Authority's notified date must occur as soon as possible and no later than eighteen months after the fiscal year end, conditioned on the Agreement and domestic filing legislation being in effect for both jurisdictions; subsequent exchanges must occur as soon as possible and no later than fifteen months after the fiscal year end. Exchanges are to be automatic using a common XML schema, and Competent Authorities must agree and notify standardised electronic transmission and encryption methods.
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Provisions expressly mentioned in the judgment/order text.
Exchange of country-by-country reports requires automatic transmission between competent authorities under agreed electronic and encryption standards.
The instrument requires specification of the currency in CbC Reports and establishes timing conditions for exchange: the first exchange for an MNE Group fiscal year commencing on or after a Competent Authority's notified date must occur as soon as possible and no later than eighteen months after the fiscal year end, conditioned on the Agreement and domestic filing legislation being in effect for both jurisdictions; subsequent exchanges must occur as soon as possible and no later than fifteen months after the fiscal year end. Exchanges are to be automatic using a common XML schema, and Competent Authorities must agree and notify standardised electronic transmission and encryption methods.
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