On 11 December 2018, the U.S. IRS published a joint statement with the competent authority of France on the spontaneous exchange of Country-by-Country (CbC) reports for reporting fiscal years beginning in 2017. The joint statement is essentially the same as the statement published for the 2016 reporting fiscal year and provides that CbC reports will be exchanged pursuant to Article 27 (Exchange of Information) of the 1994 France-U.S. tax treaty, as amended, for fiscal years of MNE Groups commencing on or after 1 January 2017 and before 1 January 2018. Where the CbC report of a U.S. MNE group has been spontaneously exchanged with France, no constituent entities of that group will be subject to a local filing obligation in France.
The joint statement also notes that the U.S. and France are still negotiating a competent authority arrangement to allow for the automatic exchange of CbC Reports.
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