DAC4/Country-by-Country (CbC) Reporting
When and how the information is exchanged
Revenue exchanges Country-by-Country (CbC) Reports with the competent authorities of relevant jurisdictions on a quarterly basis. This is provided that, based on information supplied in the Report, one or more constituent entities of the MNE Group are:
- resident for tax purposes
- or
- subject to tax with respect to the business carried out through a permanent establishment.
Note
Constituent entities is defined in Annex III Section 1(5) of Council Directive (EU) 2016/881.
There must be a qualifying competent authority agreement in effect by the due date for filing CbC Reports. In most cases, jurisdictions have signed the Multilateral Competent Authority Agreement (MCAA) for the exchange of CbC Reports.
You can view the list of jurisdictions that have signed up to the MCAA.