According to an update to the IRS CbC Reporting Jurisdiction Status Table, the Country-by-Country (CbC) Report exchange agreement and related competent authority arrangement with German became operative on 4 April 2023.
As established in the arrangement, pursuant to the provisions of Article 26 (Exchange of Information and Administrative Assistance) of the 1989 U.S.-Germany tax treaty, each competent authority intends to automatically exchange CbC reports received from each reporting entity…