Common Contracts

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE FEDERAL REPUBLIC OF GERMANY ON THE EXCHANGE OF COUNTRY-BY-COUNTRY REPORTS

March 30th, 2023

• Filed
  March 30th, 2023

Whereas the Government of the United States of America and the Government of the Federal Republic of Germany concluded an Agreement on the Exchange of Country-by-Country (CbC) Reports at Berlin on August 14, 2020 (the “Agreement”);

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF SINGAPORE ON THE EXCHANGE OF COUNTRY- BY-COUNTRY REPORTS

October 1st, 2020

• Filed
  October 1st, 2020

Whereas the Government of the United States of America and the Government of the Republic of Singapore (“Singapore”) desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF [FORMAL NAME OF JURISDICTION]

May 5th, 2020

• Filed
  May 5th, 2020

Whereas the Government of the United States of America and the Government of [Formal Name of Jurisdiction] desire to increase international tax transparency and improve access of their respective tax authorities to information regarding global allocation of the income, taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE KINGDOM OF DENMARK

May 5th, 2020

• Filed
  May 5th, 2020

Whereas the Government of the United States of America and the Government of the Kingdom of Denmark desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country‐by‐country reports (“CbC Reports”), with a view to assessing high‐level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE SLOVAK REPUBLIC

May 5th, 2020

• Filed
  May 5th, 2020

Whereas the competent authority of the United States and the competent authority of Slovakia (the “Competent Authorities”) desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF [FORMAL NAME OF JURISDICTION]

May 5th, 2020

• Filed
  May 5th, 2020

Whereas the Government of the United States of America and the Government of [Formal Name of Jurisdiction] desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF HUNGARY

January 28th, 2019

• Filed
  January 28th, 2019

Whereas the Government of the United States of America and the Government of Hungary concluded an Agreement on the Exchange of Country-by-Country Reports on 25th October 2018 at Budapest (the “Agreement”)

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF GIBRALTAR ON THE EXCHANGE OF COUNTRY-BY-COUNTRY REPORTS

January 28th, 2019

• Filed
  January 28th, 2019

Whereas the Government of the United States of America and the Government of Gibraltar desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF INDONESIA

July 24th, 2018

• Filed
  July 24th, 2018

Whereas the Government of the United States of America and the Government of the Republic of Indonesia desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country‐by‐country reports (“CbC Reports”), with a view to assessing high‐level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF MAURITIUS

May 10th, 2018

• Filed
  May 10th, 2018

Whereas the Government of the United States of America and the Government of the Republic of Mauritius desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF CROATIA

February 8th, 2018

• Filed
  February 8th, 2018

Whereas the Government of the United States of America and the Government of the Republic of Croatia desire to increase international tax transparency and improve access of their respective tax authorities to information regarding global allocation of the income, taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF POLAND

January 5th, 2018

• Filed
  January 5th, 2018

Whereas the Government of the United States of America and the Government of the Republic of Poland desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE PORTUGUESE REPUBLIC

November 3rd, 2017

• Filed
  November 3rd, 2017

Whereas the Government of the United States of America and the Government of the Portuguese Republic desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF ITALY

October 12th, 2017

• Filed
  October 12th, 2017

Whereas the Government of the United States of America and the Government of the Republic of Italy desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF ESTONIA

August 8th, 2017

• Filed
  August 8th, 2017

Whereas the Government of the United States of America and the Government of Republic of Estonia desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE SLOVAK REPUBLIC AND THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA

July 17th, 2017

• Filed
  July 17th, 2017

Whereas the competent authority of Slovakia and the competent authority of the United States (the “Competent Authorities”) desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF LATVIA

July 13th, 2017

• Filed
  July 13th, 2017

Whereas, the Government of the United States of America and the Government of the Republic of Latvia desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE KINGDOM OF BELGIUM

July 13th, 2017

• Filed
  July 13th, 2017

Whereas the Government of the United States of America and the Government of the Kingdom of Belgium desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF AUSTRALIA

July 11th, 2017

• Filed
  July 11th, 2017

Whereas, the Government of the United States of America and the Government of Australia desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE ISLE OF MAN

June 26th, 2017

• Filed
  June 26th, 2017

Whereas the Government of the United States of America and the Government of the Isle of Man desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE