U.S. and South Africa to Exchange CbC Reports

On June 5, the South African Revenue Service (SARS) released the text of an arrangement between the United States of America and the Republic of South Africa on the exchange of Country-by-Country (CbC) Reports.

Exchange of Country-by-Country Reports

The agreement states that the countries aim to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of income, taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups operate. It also allows to assess high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis.

Agreement Content

The arrangement contains the following sections:

  1. Definitions
  2. Exchange of Information with Respect to MNE Groups
  3. Time and Manner of Exchange of Information
  4. Collaboration on Transmission and Errors
  5. Confidentiality, Data Safeguards and Appropriate Use
  6. Consultations
  7. Modifications
  8. Term of Arrangement

The agreement was signed on May 8, 2017 in Pretoria and May 26, 2017 in Washington D.C.

Sources: The Agreement



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