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Germany Ratifies CbC Exchange Agreement with U.S. — Orbitax Tax News & Alerts

Germany published the Law for the ratification of the Country-by-Country (CbC) Report exchange agreement with the U.S. in the Official Gazette on 15 March 2023. The agreement was signed on 14 August 2020 and will enter into force once Germany has notified the U.S. that it has completed all necessary internal procedures for the agreement's entry into force. However, the exchange of information under the agreement will not commence until a competent authority arrangement for exchange becomes operative.

Note that the competent authorities of Germany and the U.S. have issued annual joint statements under which the U.S. has agreed to the spontaneous exchange of CbC reports with Germany so that U.S. MNEs may avoid local filing obligations in Germany. The latest statement covers reporting fiscal years beginning in 2021.