Common Contracts

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE CAYMAN ISLANDS

Arrangement on the Exchange of Country-by-Country Reports • March 15th, 2018

• Contract Type
  Arrangement on the Exchange of Country-by-Country Reports
• Filed
  March 15th, 2018

Whereas the Government of the United States of America and the Government of the Cayman Islands desire to increase international tax transparency and improve access to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) having a Reporting Entity resident for tax purposes in the Cayman Islands operate through the automatic exchange of annual country-by-country reports (“CbC Reports”) by the Competent Authority of the Cayman Islands (“Cayman Islands Competent Authority”) with the Competent Authority of the United States of America (the “United States Competent Authority”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;