1 February 2019
The Council of Europe has published three declarations from Estonia, Peru, and Portugal on the effective date for exchange of information under the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country reports (CbC MCAA) and the Mutual Assistance Convention. Each declaration includes that the respective countries intend to begin the automatic exchange of CbC reports as of 2018 and for the purpose CbC report exchange, the countries consider that the Convention is effective irrespective of the taxable period to which the information relates. This only applies in relation to other jurisdictions that have made a similar declaration and is meant to relieve local filing requirements for MNE's whose ultimate parent is resident in a jurisdiction that has signed the CbC MCAA and ratified the Mutual Assistance Convention, but for which the Convention is not yet effective for general exchange purposes.
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