According to recent reports, Hong Kong and Malta have signed a Memorandum of Understanding on the exchange of Country-by-Country (CbC) Reports. The MoU provides that CbC reports filed by Hong Kong MNE groups in Hong Kong for the 2017 and 2018 fiscal years will be exchanged with Malta in accordance with the exchange provisions of the 2011 tax treaty between the two jurisdictions, and given that exchange, Malta will not require local filing of CbC reports in Malta by such MNE groups. Further, t…