The U.S. IRS published has joint statements with the competent authorities of France and Germany on the implementation of the spontaneous exchange of country-by-country (CbC) reports. The joint statement with France is for fiscal years beginning in 2020 and 2021, while the joint statement with Germany is just for fiscal years beginning in 2020. Such joint statements were made for 2016, 2017, 2018, and 2019 as well.
The joint statement with France provides that CbC Reports for fiscal years o…