US agrees to exchange country-by-country tax reports with Spain, announces effective dates of Malta and Guernsey agreements

The US has signed a competent authority agreement with Spain to exchange country-by-country tax reports on multinational firms, the IRS announced December 20. The IRS also announced the effective dates of competent authority agreements the US signed with Malta and Guernsey.

All three agreements bear an effective date of December 19, the IRS said.

The competent authority agreements implement action 13 of OECD/G20 base erosion profit shifting (BEPS) plan, agreed to by nations in 2015. The scheme is designed to give countries’ tax agencies information about multinational firms to determine if there is a risk that multinationals are engaging in tax avoidance through transfer pricing or other means.

Information exchanged will include the firm’s global allocation of the income, taxes paid, and other information indicating multinational’s economic activity.

The first country-by country reports will relate to fiscal years that begin on or after January 1, 2016. These reports must be exchanged within 18 months following that last day of the MNE’s 2016 fiscal year. In succeeding years, the reports must be exchanged no later that 15 months after the last day of the fiscal year.


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