The U.S. IRS has published a joint statement with the competent authority of Germany on the implementation of the spontaneous exchange of country-by-country (CbC) reports for fiscal years beginning in 2021. The joint statement provides that CbC Reports for fiscal years of MNE Groups commencing on or after 1 January 2021 and before 1 January 2022 will be spontaneously exchanged pursuant to Article 26 (Exchange of Information and Administrative Assistance) of the 1989 Germany-U.S. income and c…