Arrangement on the Exchange of Country-by-Country Reports Sample Contracts

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE STATE OF ISRAEL

Arrangement on the Exchange of Country-by-Country Reports • May 16th, 2023

• Contract Type
  Arrangement on the Exchange of Country-by-Country Reports
• Filed
  May 16th, 2023

Whereas the Government of the United States of America and the Government of the State of Israel desire to increase international tax transparency and improve access of their respective tax authorities 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”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), 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;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF INDIA ON THE EXCHANGE OF COUNTRY-BY- COUNTRY REPORTS

Arrangement on the Exchange of Country-by-Country Reports • May 22nd, 2019

• Contract Type
  Arrangement on the Exchange of Country-by-Country Reports
• Filed
  May 22nd, 2019

Whereas the Government of the United States of America and the Government of the Republic of India concluded an Agreement on the Exchange of Country-by-Country Reports on 27th March, 2019 at New Delhi (the “Agreement”);

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE ARGENTINE REPUBLIC

Arrangement on the Exchange of Country-by-Country Reports • February 8th, 2021

• Contract Type
  Arrangement on the Exchange of Country-by-Country Reports
• Filed
  February 8th, 2021

Whereas the Government of the United States of America and the Government of the Argentine Republic desire to increase international tax transparency and improve access of their respective tax authorities 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”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), 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;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF BERMUDA

Arrangement on the Exchange of Country-by-Country Reports • January 10th, 2018

• Contract Type
  Arrangement on the Exchange of Country-by-Country Reports
• Filed
  January 10th, 2018

Whereas the Government of the United States of America and the Government of Bermuda 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 Bermuda operate through the automatic exchange of annual country- by-country reports (“CbC Reports”) by the Competent Authority of Bermuda (the “Bermuda 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;

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;