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Competent Authority Agreement allowing the CbCR exchange between the USA and Turkey has been signed

Tax | Transfer Pricing Bulletins 2021/1 | CbCR, Internal Revenue Service

As it is known, the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports was approved with the Presidential Decree No. 3038 published in the Official Gazette dated 1 October 2020 and numbered 31261 (Repeated), which allows the automatic exchange of Country-by-Country Reports with other countries administrations. Following this, the activation process has begun to be completed rendering the data transfer between tax jurisdictions.

In the meanwhile, a separate activation process has been going on with Turkey and the USA, which did not want to be a party to the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports and preferred to make separate bilateral agreements with the relevant countries for the automatic exchange of such information.

With the latest information available on the Internal Revenue Service (IRS) website, the bilateral competent authority agreement that allows the information exchange between Turkey and the USA for CbCR is signed on 24 November 2021. Under this scope, the information exchange for CbCR will take place pertaining to accounting periods that are starting from 01.01.2019 and thereafter.

As a consequence of the signed information exchange agreement, the Group entities of the USA based MNE’s residing in Turkey are no longer obligated to submit the Country-by-Country Reports of the Group that they are affiliated with.

The detailed information is accessible for the MNE’s being resident in the USA on the website of the IRS at the address below: 

Country by Country Reporting Status | Internal Revenue Service

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Özlem Güç Alioğlu

Özlem Güç Alioğlu

Transfer Pricing Services, Partner, PwC Turkey

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