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Update – CbC Exchange Agreement between Hungary and the U.S. — Orbitax Tax News & Alerts

The Hungarian Parliament is currently considering the ratification of the agreement on the exchange of Country-by-Country (CbC) reports signed with the U.S. on 25 October 2018. The agreement is unique in that it provides that CbC reports will be automatically exchanged but it does not contain the provisions for exchange. Instead, it includes that a separate competent authority arrangement (CAA) for the exchange of CbC reports will be signed to provide for the scope of exchange, time and manner of exchange, etc.

The agreement will enter into force once Hungary informs the U.S. that its internal procedures for bringing it into force have been completed, although the exchange of CbC reports under the agreement will not commence until the CbC CAA between the competent authorities is operative (effective).