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Activated exchange relationships for Country-by-Country reporting

 

This section shows all bilateral exchange relationships that are currently in place for the automatic exchange of CbC reports between tax authorities. 

As of March 2024, there are over 4300 bilateral exchange relationships activated with respect to jurisdictions committed to exchanging CbC reports, and the first automatic exchanges of CbC reports took place in June 2018. These include exchanges between the 101 signatories to the CbC Multilateral Competent Authority Agreement, between EU Member States under EU Council Directive 2016/881/EU and between signatories to bilateral competent authority agreements for exchanges under Double Tax Conventions or Tax Information Exchange Agreements, including 41 bilateral agreements with the United States. Jurisdictions continue to negotiate arrangements for the exchange of CbC reports and the OECD will publish regular updates, to provide clarity for MNE Groups and tax administrations.

For each exchange relationship, the legal basis and, where appropriate, the effective date and/or the activation date are shown. 

 

The table below will be regularly updated as further jurisdictions activate their bilateral exchange relationships.

 

Further information

 

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