The U.S. IRS has published the competent authority arrangement on the exchange of Country-by-Country (CbC) Reports with Germany. According to the IRS CbC Reporting Jurisdiction Status Table, the arrangement was signed on 24 March 2023, although the operative date is "To be determined".
The arrangement provides that 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 automat…