On 27 January 2016, 31 countries, including the UK, signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports so as to implement the Final Recommendations of BEPS Action 13.
Through Country-by-Country (CbC) reporting, the tax authorities of jurisdictions (party to the MCAA) where a company within a multinational group operates will receive aggregate information annually. This will begin with 2016 accounts and will cover information relating to the global allocation of income and taxes paid, along with other indicators pointing to the location of economic activity within the multinational group. It will also cover information about which entities do business in a particular jurisdiction and the business activities in which each entity engages. The information will be collected by the country of residence of the multinational group, and will then be exchanged through exchange of information supported by MCAA. First exchanges will start in 2017-2018 on 2016 information.
The 31 jurisdictions signing the MCAA are: Australia, Austria, Belgium, Chile, Costa Rica, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Japan, Liechtenstein, Luxembourg, Malaysia, Mexico, Netherlands, Nigeria, Norway, Poland, Portugal, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Switzerland and United Kingdom.
This article appears in the JHA February 2016 Tax Newsletter, which also features:
