On April 20, 2016 the OECD issued a press release announcing that Bermuda signed the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country reports (CbCR MCAA). By doing so Bermuda became the 33rd signatory of the CbCR MCAA.
The purpose of the CbCR MCAA is to enable consistent and swift implementation of new transfer pricing reporting standards that were developed under Action 13 of the BEPS Action Plan.
The goal of the CbCR MCAA is that via the Country-by-Country reporting tax administrations, where a company operates, will get aggregate information annually, starting with 2016 accounts, relating to the global allocation of income and taxes paid, together with other indicators of the location of economic activity within the MNE group. The report will also cover information about which entities do business in a particular jurisdiction and the business activities each entity engages in. The information will be collected by the country of residence of the MNE group, and will then be exchanged through exchange of information supported by such agreements as signed today. According to the OECD, the first exchanges will start in 2017-2018 on 2016 information.
Click here to be forwarded to the text of the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country Reports as available on the website of the OECD, which will open in a new window.
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