Country-by-country reports consultations require competent authorities to resolve exchange or interpretive issues with Coordinating Body notification. Section 6 provides a consultation mechanism whereby competent authorities consult when CbC report based adjustments cause undesirable economic outcomes or when difficulties in implementing or interpreting the Agreement arise; prior consultation is required before declaring a systemic failure to exchange CbC Reports, such determinations are notified to the Coordinating Body Secretariat which circulates conclusions or measures to all competent authorities, and taxpayer specific identifying information must not be disclosed.
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 reports consultations require competent authorities to resolve exchange or interpretive issues with Coordinating Body notification.
Section 6 provides a consultation mechanism whereby competent authorities consult when CbC report based adjustments cause undesirable economic outcomes or when difficulties in implementing or interpreting the Agreement arise; prior consultation is required before declaring a systemic failure to exchange CbC Reports, such determinations are notified to the Coordinating Body Secretariat which circulates conclusions or measures to all competent authorities, and taxpayer specific identifying information must not be disclosed.
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