On June 5, 2017 the South African Revenue Service (SARS) released the text of an arrangement between the competent authority of the United States of America and the competent authority of the Republic of South Africa on the exchange of Country-by-Country Reports. According to SARS the agreement was signed on May 8, 2017 in Pretoria and May 26, 2017 in Washington D.C.

The first Fiscal Year for which the U.S. and South Africa intend to exchange CbC Reports is for the Fiscal Years of MNE Groups commencing on or after January 1, 2016. Such CbC Report is intended 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 (for later Fiscal Years a 15 month period applies).

The arrangement contains the following sections:

SECTION 1 - Definitions

SECTION 2 - Exchange of Information with Respect to MNE Groups

SECTION 3 - Time and Manner of Exchange of Information

SECTION 4 - Collaboration on Transmission and Errors

SECTION 5 - Confidentiality, Data Safeguards and Appropriate Use

SECTION 6 - Consultations

SECTION 7 - Modifications

SECTION 8 - Term of Arrangement

Click here to be forwarded to the text of the arrangement as available on the website of SARS.

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