U.S. Competent Authority: U.S., Monaco Joint Arrangement on CbC Reporting (IRC §482)

Arrangement by Competent Authorities of the United States and Monaco sets forth parameters on the exchange of county-by-country (CbC) reporting agreement to combat transfer pricing and base erosion and profit shifting related risks, the U.S. Office of Competent Authority posted November 30. Each Competent Authority intends to exchange with the other Competent Authority annually on an automatic basis the CbC Report received from each Reporting Entity that is resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC Report, one or more Constituent Entities of the MNE Group of the Reporting ...