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U.S. IRS Publishes CbC Exchange Arrangement with Indonesia

The U.S. IRS has published the bilateral competent authority arrangement on the exchange of Country-by-Country (CbC) reports with Indonesia. The arrangement was signed 13 June 2018 and is operative (effective) from that date.

The arrangement provides that pursuant to Article 26 (Exchange of Information) of the 1988 Indonesia-U.S. tax treaty, each competent authority intends to automatically exchange CbC reports received from each reporting entity 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 entity are resident for tax purposes in the jurisdiction of the other competent authority, or are subject to tax with respect to the business carried out through a permanent establishment situated in the other jurisdiction.

With respect to fiscal years beginning on or after 1 January 2016, CbC reports are to be exchanged as soon as possible and no later than 18 months after the last day of the fiscal year of the MNE Group to which the CbC report relates, and with respect to fiscal years beginning on or after 1 January 2017, reports are to be exchanged no later than 15 months after the last day of the fiscal year. However, the competent authorities have until three months after the arrangement is operative (13 June 2018) to first exchange reports

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