Country-by-country reporting: automatic exchange of CbC Reports among competent authorities with confidentiality and use limits. The Notification adopts the Multilateral Competent Authority Agreement, establishing automatic exchange of annual Country-by-Country Reports filed by Reporting Entities of MNE Groups among Competent Authorities where Constituent Entities are resident or taxed through permanent establishments, subject to reciprocity notifications, timing and transmission standards, domestic filing legislation, confidentiality and data use limitations for high level transfer pricing and BEPS risk assessment, consultation mechanisms for undesirable economic outcomes and provisions for suspension, amendment and termination of exchange relationships.
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Country-by-country reporting: automatic exchange of CbC Reports among competent authorities with confidentiality and use limits.
The Notification adopts the Multilateral Competent Authority Agreement, establishing automatic exchange of annual Country-by-Country Reports filed by Reporting Entities of MNE Groups among Competent Authorities where Constituent Entities are resident or taxed through permanent establishments, subject to reciprocity notifications, timing and transmission standards, domestic filing legislation, confidentiality and data use limitations for high level transfer pricing and BEPS risk assessment, consultation mechanisms for undesirable economic outcomes and provisions for suspension, amendment and termination of exchange relationships.
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